Sure, there are some from other courts elsewhere, but they are few and far between, and Starr really wouldn't be able to cite them properly in a brief in the District of Columbia.
Starr would be able to cite all things from the other courts in a brief in the District of Columbia. 
mnli hypothesis: Starr would be able to cite all things from the other courts in a brief in the District of Columbia.  premise: Sure, there are some from other courts elsewhere, but they are few and far between, and Starr really wouldn't be able to cite them properly in a brief in the District of Columbia.