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Va'eira(Exodus 6:2-9:35)

Frogs

God sends a message to Pharoh to release His people. The message is ridiculed and rejected. God then tells Moshe of the plan to strike Egypt with blood, and the plagues begin. While the transformation of water to blood should have been intimidating, when the magicians of Egypt manage to replicate this on a small scale (ironically bringing even more blood to Egypt), Pharoh is invigorated and once again refuses to comply. This sets the stage for the second plague.

And God said to Moshe, 'Go to Pharoh, and say to him, Thus said the Lord, Let my people go, that they may serve me. And if you refuse to let them go, behold, I will plague all your borders with frogs. And the river shall bring forth frogs abundantly, which shall go up and come into your house, and into your bed chamber, and upon your bed, and into the house of your servants, and upon your people, and into your ovens, and into your kneading troughs. And the frogs shall come up both on you, and upon your people, and upon all your servants. And God said to Moshe, Say to Aharon, Stretch forth your hand with your rod over the streams, over the rivers, and over the ponds, and cause frogs to come up upon the land of Egypt. And Aharon stretched out his hand over the waters of Egypt; and the frog(s) came up, and covered the land of Egypt. (Sh'mot 7:26-8:2)

It is difficult to discern subtleties of language in translation, but there is an oddity which is striking in Hebrew: In the prologue to the plague, the amphibious creature is called tzfarde'im (frogs) in the plural, while in verse 2, when Aharon stretches out his hand, the text reads tzfarde'a (frog) in the singular.

Rashi offers two interpretations to reconcile the usage of both the singular and the plural. In the first interpretation, Rashi explains that both terms are accurate: In fact, only one frog emerged from the water (clearly an enormous frog, as it covered all of Egypt). This one frog was then hit repeatedly, but rather than dying of its wounds or beating a retreat, it multiplied or reproduced spontaneously, "streaming forth swarms and swarms of frogs". Rashi admits that this is a Midrashic explanation, and then offers a second interpretation based on the straightforward, more literal meaning of the text. He theorizes that it is linguistically acceptable to use the singular form when referring to the plural of certain species of animals, as in the case of "fish" or "sheep" in English.1 While this second explanation is rational and logical, it suffers from one major weakness: If the singular form of frog denotes the plural, why was the plural form used in the preceding verses? This problem seems to have been the reason Rashi offered the alternative, Midrashic interpretation as well.

The Midrashic source for Rashi's interpretation is itself comprised of two opinions, but with a very important shift:

AND THE FROG(S) CAME UP, AND COVERED THE LAND OF EGYPT. Rabbi Akiva said: It was only one frog, but this bred so rapidly that it filled the land of Egypt. Rabbi Elazar Ben Azariah said to him: 'Akiva! What business have you with Haggadah? Leave homiletical interpretations and turn to Neg'aim and Ohalot! Indeed, there was one frog at first, but it croaked to the others and they came.' (Midrash Rabba Sh'mot 10:4)

If we were expecting a debate between a rationalist and a metaphysician, we would be sorely disappointed, even though it sounded promising at first: Rabbi Akiva opines that there was but one frog, and via spontaneous reproduction, the frog spread throughout Egypt. When Rabbi Elazar ben Azarya chastises Rabbi Akiva, saying "What business have you with Haggadah?", one would think that the object of his ire was Akiva's fantastic interpretation. Indeed, the advice he gives Rabbi Akiva, to redirect his intellectual efforts to matters of clear-cut halachic inquiry, seems wholly understandable. But then, Rabbi Elazar offers his own approach, and it seems quite similar to that of Rabbi Akiva: there was one frog - but it called its friends in to help. It is very hard for us to see the superiority of this second approach, and why Akiva was encouraged to abandon this type of study. At first, we think we know where the argument between Rabbi Akiva and Rabbi Elazar ben Azarya is going, but Rabbi Elazar's final statement, the "bottom line" of his argument, casts the earlier rebuke in a new light, making what we thought was clear seem mystifying. In stark distinction to the two opinions cited by Rashi, here the distinction seems to be less a divergence between rationalism and metaphysics and more a matter of degrees. What, then, could the reason for Rabbi Elazar's rebuke have been, given that his own analysis of the text is not radically different from the interpretation he rejects?

The Hassidic masters offer an overall view of the plagues that may help us to understand the argument between Rabbi Elazar and Rabbi Akiva, as well as giving us insight into the plague of frogs in general and to our grammatical query in particular.

Rebbi Kalonymus Kalman Epstein (1754-1823) (in his Maor Vashemesh) explains our particular problem in the context of his larger understanding of the plagues. According to the mystical tradition he received from his masters,2 the purpose of the plagues was to establish the truth of God's existence on Earth: Had God so desired, He could have simply and effortlessly removed the Israelites from Egypt. Apparently, there is great theological purpose to the plagues.

In this mystical tradition, the Ten Plagues are parallel to the ten kabbalistic Sefirot, in reverse sequence. The first plague, blood, was parallel to Malchut, Kingship: God is King of the Universe. The Egyptians believed that the Nile was the life force of Egypt, and the Nile was in turn created by Pharaoh.3 Therefore, turning their beloved Nile to blood was a direct attack on the beliefs and superstitions of the Egyptians, a means of making God's mastery of the physical universe apparent.4

Following this line of thought, the next plague, frogs, would counter the next Sefira - Yesod. This is the spiritual power that connects the higher world with the lower world - heaven and earth. Rebbi Nachman of Breslov (1772 -1810), and Rebbi Kalonymus Kalman, both building upon a tradition found in the Tana D'beh Eliyahu and the writings of the Arizal5 as transmitted by the Baal Shem Tov,6 note that the word frog, tzfarde'a, can have more than one meaning, especially when we de-construct it into its two elemental words.7 The word tzfarde'a (frog) is a combination derived of tzipor (bird) and de'a (knowledge).8 Thus, a "frog" is a "knowledgeable bird", turning the tzefarde'a from an amphibian into a flying creature that could reach up to the heavens.9

Rebbi Nachman actually takes this same tradition in a slightly different direction. Birds possess two unique abilities: flight and song. While we have seen that the ability to fly is germane to the spiritual identification of this plague with the Sefira Yesod, connecting heaven and earth, Rebbi Nachman focuses on the bird's other unique attribute - its ability to sing.10 What may sound to some as the croaking of a frog may be perceived as the beautiful song of a bird. Indeed, the "beautiful singing" of the frog silenced the Psalmist, King David himself. The Midrash recounts that when David completed the Book of Psalms, he experienced momentary pride and asked God, "Is there anything in this world that sings songs as beautiful as these to You?" God brought forth a frog, to teach David that the song of the frog surpasses David's Psalms.11

Aside from the Hassidic tradition, rabbinic sources have quite a lot to say about what might otherwise have been considered one of the lowliest of creatures. Apparently, its' beautiful song is not the frog's only claim to fame; according to rabbinic sources, the frogs of Egypt served as inspiration for others in the future who would face perilous situations with heroism and bravery.

When the Torah describes the plague of frogs, the scope of the infestation is very precisely detailed: "And the river shall bring forth frogs abundantly, which shall go up and come into your house, and into your bed chamber, and upon your bed, and into the house of your servants, and upon your people, and into your ovens, and into your kneading troughs." Of all the points of infiltration, the oven is clearly not the most innocuous - from the perspective of the frog. Entering a hot oven can be unpleasant at least, excruciating and fatal at worst. Yet God commanded that the ovens be filled with frogs, and the frogs complied and entered the hot ovens, along with or instead of the kneaded dough:

AND INTO YOUR KNEADING-TROUGHS…Now when does the dough begin to cling to the oven? When one heats the oven. Hananiah, Mishael, and Azariah reasoned from the case of the frogs when they descended into the fiery furnace. (Midrash Rabbah Shmot 10:2)

Generations later, when faced with a situation of martyrdom, Hananiah, Mishael, and Azariah take their cue -- not from Avraham who was thrown into Nimrod's furnace, but from the frogs who jumped into the hot ovens of Egypt because God said they must.

The author of this teaching is a man named Todos of Rome, who apparently was a leader of the community and was considered a great man by the scholars of the Talmud.

The scholars asked: Was Todos of Rome a great man or a powerful man? - Come and hear: This too did Todos of Rome teach: What [reason] did Hananiah, Mishael and Azariah see that they delivered themselves, for the sanctification of the [Divine] Name, to the fiery furnace? They argued a minori to themselves: if frogs, which are not commanded concerning the sanctification of the [Divine] Name, yet it is written of them, 'and they shall come up and go into your house . . . and into your ovens, and into your kneading troughs': when are the kneading troughs to be found near the oven? When the oven is hot. We, who are commanded concerning the sanctification of the Name, how much the more so. (Talmud Bavli Pesachim 53b)

Todos explains the precedent set by the frogs: Though they were not halachically obligated to do so, they chose martyrdom to sanctify God's name. It stands to reason, then, that those who are halachically obligated should do no less. In another source the matter is explained with sensitivity to nuance: The frogs had no ancestral merit upon which to rely for salvation, yet they nonetheless chose to endanger themselves; we, who rely on the merit of our forefathers, cannot but endanger ourselves likewise, with the hope that our ancestral merit will save us.12

The question of martyrdom is a very complex issue in Jewish law: When is the ultimate self-sacrifice an obligation, and when is it a subject of choice? This very issue is the enduring lesson of the frogs, who were not absolutely obligated to martyr themselves, yet nonetheless knowingly made the ultimate sacrifice.

Keeping this philosophical debate in mind, we now turn to another discussion between Rabbi Akiva and Rabbi Elazar Ben Azarya. In a celebrated passage found in the Passover Haggada we find these two rabbis, along with several of the most important Jewish leaders of that age, having their Seder together:

It once happened that Rabbi Eliezer, Rabbi Yehoshua, Rabbi Elazar ben Azarya, Rabbi Akiva and Rabbi Tarfon were reclining (during the Passover Seder) in Bnei Braq and they were engaged in the story of the Exodus through that entire night, until their students came and said, "Rabbis, it is time for the morning Shma".

Why did these Rabbis abandon normative Jewish practice and eschew their obligations to educate their own children and families at their respective Seders, and instead spend this holy night with colleagues? This particular passage has been preserved only in the Passover Haggadah, the primary source lost. However, extant parallel sources are instructive. The Tosefta records a similar Seder:

It once happened that Raban Gamliel and the sages reclined (during the Passover Seder) in the home of Bitus the son of Zunin in Lod and they were involved in the study of the laws of the Pesach all night until the rooster crowed. They then knew it was time to go to the study hall. (Tosefta Pesachim, Chapter 10)

In this instance, a number of Torah scholars gather, this time in Lod. The only protagonist mentioned by name is Raban Gamliel, who was absent in the Haggadah version. This particular account shares certain elements with other Passover evenings celebrated in Lod, with some more familiar celebrants, as related in various other sources:

Rabbi Tarfon and the Elders were once reclining in the upper storey of Nithza's house, in Lod, when this question was raised before them: Is study greater, or practice? Rabbi Tarfon answered: Practice is greater. R. Akiva answered: Study is greater. Then they all answered and said: Study is greater, for study leads to action. (Talmud Bavli Kiddushin 40b)

Here, too, the location is Lod, but the particular venue is an attic. The question posed to this lofty forum sounds somewhat academic: What is more important, learning or action? Theory or reality? Again, why are the sages discussing this on Pesach night?13 Why are they together and not with their families? Why are they sitting in an attic? This particular attic is known from another passage, where a major policy issue is discussed: When should martyrdom be undertaken?

R. Yohanan said in the name of R. Simeon b. Yehozadak: By a majority vote, it was resolved in the attic of the house of Nithza in Lod that in every [other] law of the Torah, if a man is commanded: 'Transgress and suffer not death' he may transgress and not suffer death, excepting idolatry, incest, [which includes adultery] and murder. (Sanhedrin 74a)

It is the same attic, but now it is obvious that the question posed is a life and death question. When is a Jew obligated to give up his or her life? When is martyrdom a requirement? This question was discussed, debated and voted upon in an attic in Lod. Why not out in the open? Why was the debate and discourse not public, in the normal venues for Talmudic study? When we consider the time and place this discussion took place we begin to realize that this was not a question of theory, it was a question of practice. The ruthless Romans had imposed decree after decree. Eventually the very study of Torah was outlawed. "Where do we draw the line?", the gathered Sages ask. When is a person obligated to fight? When is a person obligated to surrender? When is it permissible to knowingly put oneself in a situation that is undoubtedly dangerous? Tragically, in that generation, these questions became commonplace. The Rabbis had to discuss, debate and vote, but the discussion could not be public--not when a rebellion was either in the air or already underway.

Life had changed. Things had become complicated. Meetings were held in secret, and the decisions shared covertly. The Rabbis apparently looked for the best time to hold such discussions, and chose a window of holiness, a night that was blessed and empowered with the ability to safeguard Jews from peril. They chose the night that redemption - both past and future- is the main topic of discussion: Pesach. They, too, were discussing redemption, looking to the past redemption and taking cues for the future redemption.14 Our Pesach tradition includes a call to empathy and identification: In each and every generation, the Jew is commanded to insert him or her self into the story of our national redemption, to attempt to visualize and thereby take part in the stages of slavery and freedom our forefathers experienced in Egypt.15 When these Rabbis gathered together, they surely felt and understood that historic slavery and the archetypical liberation. Even more pointedly, they dealt with the pain of their own current affliction, and undoubtedly tried to envision, to sense, even to hasten the future redemption. Unfortunately, the path to future redemption was paved with resistance and martyrdom. And so, while it would have been nice to enjoy a pleasant holiday feast with family, the future of the nation hinged upon the life and death decisions reached that holy night in the attic in Lod.

When discussing martyrdom, the rabbis concluded that there are times when one is required to give one's life. The proof-text invariably brought for this ruling is the verse which commands us to love God with all our soul:

For it has been taught, R. Eliezer said: And you shall love the Lord your God with all your heart and with all your soul, and with all your resources. Since 'with all your soul' is stated, why is 'with all your resources' stated? Or if 'with all your resources' be written, why also write 'with all your soul'? For the man to whom life is more precious than wealth, 'with all your soul' is written; while he to whom wealth is more precious than life is bidden, 'with all your resources' [i.e., substance]. (Sanhedrin 74a)

This verse is found in the prayer called Shma. Perhaps, in the story transmitted in our Pesach Haggadah, this is the meaning of the passage "until the students came and said "Rabbis, it is time for the morning Shma"! This story took place in Bnei Braq, Rabbi Akiva's hometown; these were his students.16 What these students seem to be saying is, "Rabbis, it is time for the morning Shma - it is time to love God with all our hearts, with all our souls, with all we have, even our lives. It is time for martyrdom." And so it was: When the time came for Rabbi Akiva to be martyred, the Shma was on his lips, for the Talmud explains that it was, indeed, "time for Shma:"

When Rabbi Akiva was taken out for execution, it was the hour for the recital of the Shma, and while they combed his flesh with iron combs, he was accepting upon himself the Kingship of Heaven. His students said to him: Our teacher, even to this point? He said to them: All my days I have been troubled by this verse, 'with all your soul', [which I interpret,] 'even if He takes your soul'.17 I said: When shall I have the opportunity of fulfilling this? Now that I have the opportunity shall I not fulfill it? He prolonged the word ehad until he expired while saying it. A bat kol (heavenly voice) went forth and proclaimed: Fortunate are you, Akiva, that your soul has departed with the word ehad!' The ministering angels said before the Holy One, blessed be He: Such Torah, and such a reward? [He should have been] among them that die by Your hand, O Lord.' He replied to them: 'Their portion is in life.' A bat kol went forth and proclaimed, 'Fortunate are you, Rabbi Akiva, that you are destined for the life of the World to Come. (Talmud Bavli Brachot 61b)

Rabbi Akiva was martyred because he did not desist from teaching Torah when the Romans declared it illegal.18 Is this "crime" one of the three cases which would halachically require martyrdom? Was his case an obligation of martyrdom, or was it heroism? When the primary historian of the Talmudic age, Rav Sherira Gaon, describes the death of Rabbi Akiva, he writes, "Rabbi Akiva gave himself up to be killed." 19 This sounds decidedly voluntary and not obligatory.20

Perhaps we can complete the circle, returning to the strange debate between Rabbi Akiva and Rabbi Elazar ben Azarya regarding the singular or plural form of "frog".21 Rabbi Akiva, whom the Talmud says also lacked ancestral merit,22 spoke of one big frog, a frog who was tortured and beaten.23 Somehow, rather than killing this one frog, the Egyptians' abuse caused countless frogs to appear, making life unbearable for the Egyptians, and eventually resulting in the redemption of the Jewish slaves. Thus, Rabbi Akiva: despite the decrees, the beatings and imprisonment, in the face of torture, he did not succumb. His words of Torah only gathered force, creating a great wave of Jewish identity and awareness, and creating the foundations of a Jewish renaissance. Many more students appeared, "swarms" of followers, inspired both by the life and death of Rabbi Akiva.

Is Rabbi Elazar ben Azarya's admonishment actually a plea to his colleague Akiva: - "Go back to Ohalot - go back to the tents"? Is this a veiled reference to Rabbi Akiva's decision to teach publicly despite the danger?

Our Rabbis taught: Once the wicked Government issued a decree forbidding the Jews to study and practice the Torah. Pappus ben Yehuda came and found Rabbi Akiva publicly bringing gatherings together and occupying himself with the Torah. He said to him: Akiva, are you not afraid of the Government? He replied: I will explain to you with a parable. A fox was once walking alongside of a river, and he saw fishes going in swarms from one place to another. He said to them: From what are you fleeing? They replied: From the nets cast for us by men. He said to them: Would you like to come up on to the dry land so that you and I can live together in the way that my ancestors lived with your ancestors? They replied: Are you the one that they call the cleverest of animals? You are not clever but foolish. If we are afraid in the element in which we live, how much more in the element in which we would die! So it is with us. If such is our condition when we sit and study the Torah, of which it is written, 'For that is your life and the length of your days,' if we go and neglect it how much worse off we shall be! (Talmud Bavli Brachot 61b)

Is Rabbi Elazar ben Azarya pleading with Rabbi Akiva not to take the responsibility upon himself? "It was one frog, but he croaked and called the others!" Rabbi Elazar ben Azarya felt that the role of a leader is to call out to others, to build the philosophical underpinnings for the movement. Rabbi Akiva was not satisfied with this role. He adopted the conclusion of his colleagues: "What is most important, study or practice? Study that leads to practice." Study is great, theory is important, philosophy is necessary, but it must eventually lead to practice. There is a time to theorize, a time to debate and cast votes, and there is a time to act, to carry one's convictions through to reality.

We noted earlier that the frog, the "knowledgeable bird", can fly, like a soul that soars to heaven. This frog/bird can also sing. What is the song that it sings? According to the Perek Shira,24 the song of the frog is "Baruch Shem K'vod Malchuto L'Olam Va'ed": May the glorious Name of God's Kingship be blessed forever and ever.25 This line appears in our twice-daily prayers between the first sentence of Shma, which declares God's Singularity, and the first paragraph which states the obligation to love God with all ones heart, soul, and resources, even unto death. Like Rabbi Akiva, the "frog" seems to know the secret of the Shma. Like Rabbi Akiva, the frog is particularly in tune with its internal voice, and is uniquely able to distinguish between night and day: This frog knows when it is time for the Shma to be recited, when it is time to sanctify God's name with words and actions.26 As it marches into the ovens, the frog is not a frog; it is a bird. It can fly to the highest part of heaven, like a purified human soul, and sing like the greatest of our psalmists, David son of Yishai. It can say the Shma and Baruch Shem like Rabbi Akiva, and teach us about martyrdom and redemption.

 

NOTES

1. Rashi Shmot 8:2.

2. See Zohar Shmot 29a: Then followed the frogs, who with mighty squealings and croakings entered the very entrails of the Egyptians. They emerged from the river on to the dry land, where they raised a noise all around until they fell dead in the interior of the houses. Esoterically speaking, the ten plagues were wrought by the mighty hand of the Almighty, by the hand that overpowered the grades (Page 29b) of the Egyptian divinities, and confused their minds so that they remained helpless. Observe that all their grades, as soon as they emerged into the open to accomplish something that could be seen by all, became powerless to do anything.

3. This idea is expressly stated in a verse in this week's haftorah, Yechezkal 29:3 3: "Speak, and say, Thus says the Lord God: Behold, I am against you, Pharoh king of Egypt, the great crocodile that lies in the midst of his streams, who has said, My river is my own, and I have made it for myself."

4. This is also related to the Ten Commandments. The first plague addresses the same philosophical tenets as the First Commandment, "I am God…" The plague of frogs parallels the Second Commandment. See also Pri Tzaddik Kuntris al HaOchel.

5. See Shaar Hapsukim Parshat Va'era.

6. Baal Shem Tov on the Torah, Parshat Va'era: The earliest sources would appear to be the Sefer Hapliah, and the Tana D'Beh Eliyahu Chapter 7.

7. The earliest sources would appear to be the Sefer Hapliah, and the Tana D'Beh Eliyahu Chapter 7.

8. The Maharil (Minhagim Liqutim section 95), also divides the word into two tzafra and deah, but in his understanding tzafra is Aramaic for 'morning'. Hence the frog makes noise all night, but knows when the morning has come.

9. Ma'or Vashemesh Va'era.

10. Liquty Maharan Mehdura kama siman 3.

11. Perek Shira, and Yalkut Shimoni Psalms 150 section 889. This final section speaks about song. Ironically the previous section discuses the soul, and its desire to fly and leave the body and return to heaven. Again we see the same elements; singing and flying.

12. Midrash Tehilim chapter 28.

13. Admittedly the term mesubim does not necessarily mean that it was Passover; however there is certainly a common theme among these passages.

14. Others have pointed out the possibility that Rabbi Akiva and the sages were discussing the Bar Kochva rebellion. As far as I can tell, this suggestion was not raised prior to the 20th century. Of particular interest is the Pesach night celebrated in the Warsaw Ghetto immediately before the uprising. Apparently, they too discussed past and future liberation, with very practical consequences. The earliest source I located was Rabbi Y.L. Maimon. See Amram Kehati's article on the Bnei Brak Seder and its connection with the planning of the outbreak of Rabbi Akiva's revolt in Sulam Vol. 6 No. 12, Nisan 1955, pgs. 6-7.

15. Mishna Pesachim 10:5.

16. It is important to note that Rabbi Akiva was an enthusiastic supporter of Bar Kochva. See my Book "Emanations" for fuller treatment of this topic.

17. The Noam Elimelech on Parshat Chukat states that throughout Rabbi Akiva's entire life he sought to teach the lesson of sanctifying God's name and martyrdom.

18. Earlier in the passage (Brachot 61b) which describes Rabbi Akiva's death this point is made clearly. See below.

19. Letter of Rav Sherirah Gaon, Levin edition page 13, both recensions.

20. Whether one is permitted to martyr oneself when not obligated is a subject of Halachic debate. See Shulchan Oruch Yore De'ah section 156 and the various opinions of the Rambam who does not allow this, and Rabbenu Yeruchum who does. One commentator proposed that this may be the lesson Todus extrapolated from the frogs. See Yismach Moshe Parshat Ki Tisa, page 188.

21. The name Azarya adds irony to the situation, Azarya being one of the people who based on the frogs precedent decided to jump into the furnace.

22. Talmud Brachot 27b, this is the reason Rabbi Akiva was passed over for the role of Nasi, a position filled instead by Rabbi Eleazar ben Azarya.Rabban Gamaliel remained sitting and expounding and R. Joshua remained standing, until all the people there began to shout and say to Huzpith the Turgeman, Stop! and he stopped. They then said: How long is he [Rabban Gamaliel] to go on insulting him [R. Joshua]? On New Year last year he insulted him; he insulted him in the matter of the firstborn in the affair of R. Zadok; now he insults him again! Come, let us depose him! Whom shall we appoint instead? We can hardly appoint R. Joshua, because he is one of the parties involved. We can hardly appoint R. Akiba because perhaps Rabban Gamaliel will bring a curse on him because he has no ancestral merit. Let us then appoint R. Eleazar b. Azariah, who is wise and rich and the tenth in descent from Ezra. He is wise, so that if anyone puts a question to him he will be able to answer it. He is rich, so that if occasion arises for paying court to Caesar he will be able to do so. He is tenth in descent from Ezra, so that he has ancestral merit and he [Rabban Gamaliel] cannot bring a curse on him.

23. Rabbi Akiva's comment, that as the frog was tortured it multiplied, is reminiscent of the Torah text regarding the Jewish People themselves: "But the more [the Egyptians] oppressed them, the more [the Israelites] proliferated and spread." (Shmot 1:12) This certainly strengthens the identification between the frog and the Jewish people, and reveals Rabbi Akiva's encrypted message.

24. Chapter 4. This poetic work is traditionally ascribed to King David.

25. See R' Simcha Bunim of Peshischa, Kol Mevaser, part 2 Bava Kamma.

26. See footnote 8, above.

 

Published: January 17, 2009

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