Reference for Bava Kamma 110:2

נפרצה בלילה או שפרצוה לסטים ויצאה והזיקה פטור הוציאוה לסטים לסטים חייבין

IF [THE WALL] BROKE DOWN AT NIGHT, OR IF ROBBERS BROKE IN, AND THEY<span class="x" onmousemove="('comment',' I.e., the sheep. ');">³</span> GOT OUT AND DID DAMAGE, HE WOULD NOT BE LIABLE. IF [HOWEVER] ROBBERS TOOK THEM OUT [FROM THE SHED AND LEFT THEM AT LARGE AND THEY DID DAMAGE] THE ROBBERS WOULD BE LIABLE [FOR THE DAMAGE].<span class="x" onmousemove="('comment',' Done by the sheep, since they have come into the possession of the robbers, who have thus become liable to control them. ');">⁴</span>

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