with respect to his independent IAC claim, he need not do so to claim ineffective assistance for the purpose of establishing cause” for defaulting another claim); Fischetti v. Johnson, 384 F.3d 140, 154-55 (3d. Cir.2004) (same); see also Holloway v. Horn, 161 F.Supp.2d 452, 478 n. 12 (E.D.Pa.2001) (same), rev’d on other grounds by 355 F.3d 707 (3d Cir.2004); Holland v. Horn, 150 F.Supp.2d 706, 747 (E.D.Pa.2001) (same); Torrefranca v. Schriro, No. Civ-05-2909, 2006 WL 1981788, at *10 n. 5 (D.Ariz. July 13, 2006) (same). Additionally, one court in this district has adopted the reasoning of the Sixth and Third Circuits. Green v. Johnson, 2007 WL 951686, at *3 (E.D.Va. Mar.26, 2007). 29 .See Orbe v. True, 233 F.Supp.2d 749, 758 (E.D.Va.2002). 30 . See, e.g., Fischetti, 384 F.3d at 154-55 (<HOLDING>); Holloway, 161 F.Supp.2d at 476 n. 12 (stating
holding that where congress does not establish a statute of limitations applicable to a federal cause of action a void which is commonplace in federal statutory law  this court has repeatedly borrowed the state law of limitations governing an analogous cause of action holding that dismissal is proper for a derivative cause of action but not for a direct cause of action holding statutory violation sufficient cause holding that aedpa does not establish a statutory high hurdle for cause holding that a determination of probable cause does not bar a state law malicious prosecution claim where the claim is based on the police officers supplying false information to establish probable cause