Ancillary jurisdiction differs from pendent jurisdiction in that pendent jurisdiction requires the federal and non-federal claims to arise from a "common nucleus of operative fact," (per "United Mine Workers of America v. Gibbs") not to be logically interdependent.
Justice Harlan wrote a brief concurrence, in which he agreed with Brennan's discussion of pendent jurisdiction, but disagreed with his interpretation of the standard of proof required for a claim under the Norris-LaGuardia Act.
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He has since worked with a number of musicians including The Apples in Stereo, Luna, Swans, Evan Dando, Sean Lennon, Sebadoh, Heave, Come, Spacehog, Ramones, The Morning Glories, Band of Susans, Danish band Grand Avenue, Phish, The 45's, Akron Family, Dylan Connor, The Spring Standards, and cabaret pop group Antony and the Johnsons.
On 27 July 1917, he scored twice, driving down an Albatros D.V fighter on one patrol and sharing in the destruction of an Aviatik recon plane with Roger Neville on another.
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On 2 June 1917, he opened his victory roll when he drove down a German Albatros D.III fighter out of control.
He was a member of the Republican National Committee from 1896 until his death; and was President of the Metropolitan Water Company.
Kahn was also a former director of Teleregister Corp., Hugo Stinnes Co., Grand Union Stores, Kings County Lighting, West Chemical, and Willcox & Gibbs.
He was Visiting Professor in the Department of History at the University of New Brunswick in 1975-76; the United States Military Academy in 1978-79, and the National University of Singapore in 1981-82.
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In 1979, the Superintendent of the United States Military Academy, General Andrew Jackson Goodpaster awarded Gibbs the U.S. Army's Outstanding Civilian Service Medal for the superb quality of his teaching and in recognition of his many contributions as Chichele professor to military education.
# "Santa Cruzin" (John E. Blake Jr., Tyrone Brown, Leonard "Doc" Gibbs Jr., James "Sid" Simmons, Richard Lee Steacker, Millard "Pete" Vinson, Grover Washington, Jr.) — 6:54
Mainstream aviation scholars dispute the flight; in 1980, C.H. Gibbs-Smith called the story a "flight of fancy".