Midrash for Chullin 278:52
אמרה
AN UNCLEAN BIRD ONE IS NOT BOUND TO LET GO.
Sifrei Devarim
(Devarim 22:6) "If there chance before you a bird's nest": to exclude what is normally found there.
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Talmud Bavli
אמרה
AN UNCLEAN BIRD ONE IS NOT BOUND TO LET GO.