What is yuhara? What does it have to do with women and tzitzit?
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What is Yuhara? In common halachic usage, the term "yuhara," spiritual haughtiness, denounces and prohibits seemingly pious action that is opposed to established custom, like refraining from labor on a fast day when others don't, or laying tefillin in the style of Rabbeinu Tam in a place where that is not usually done.
Abudarham provides a clear definition of yuhara, cited by Beit Yosef.
Sefer Abudarham, Laws of Keri'at Shema
Any matter in which a person is not obligated and he does it in public [as though] out of piety, and the entire people do not do it, is someone who appears spiritually haughty.
By taking on pious behaviors that most Jews do not perform, a person implicitly critiques common practice and suggests that he or she has an inflated spiritual self-image.
In the late middle ages in medieval Ashkenaz, yuhara became a very central halachic preoccupation.
Yuhara and Tzitzit A number of questions of yuhara arise specifically in connection with tzitzit. For example, may a man hold his tzitzit for Keri'at Shema, or is that considered yuhara? May he wear his tzitzit out over his clothing, or is that yuhara? May he wear two sets of tzitzit, one strung regularly and one strung in accordance with a minority opinion, or is that yuhara?
Yuhara and Women Over time, it became common for women to observe positive time-bound mitzvot like hearing shofar and taking lulav, even though women are exempt from this category of mitzvot. Why was this not considered yuhara?
Ra'avya (twelfth-century Ashkenaz) explains that since the community as a whole performs these actions, they are not considered yuhara for women.
Ra'avya Section 2, Megilla 597
Regarding women, when they fulfill positive mitzvot, there is no yuhara according to all opinions, since everyone sits in the sukka and blows shofar and takes lulav... Yuhara is only applicable where one does something different from the rest of people. [This is so] even though women are exempt…
To Ra'avya, yuhara depends on acting differently from the community. It is unclear, however, what Ra'avya would say about an individual woman who fulfills a mitzva that other women don't.
Yuhara, Women, and Tzitzit
Unlike other positive time-bound mitzvot such as shofar, it seems that women never commonly observed the mitzva of tzitzit. For this reason, a woman's wearing a garment with tzitzit might be considered yuhara.
Indeed, the great 14th-15th century Ashkenazi authority Maharil pens a responsum opposing women's wearing garments with tzitzit. The issue arises when a woman in his community begins to wear a tallit katan:
Sefer Maharil Laws of Tzitzit and Tefillin 4
…He [Maharil] said that it is not clear to him that there are women who accept upon themselves the obligation of tzitzit. They asked him why he does not protest Rabbanit M[arat] Bruna in his city, who wore a tallit katan at all times. He responded that perhaps she will not heed him, and regarding this type of situation he said, "Better that they should stray unwittingly than that they should do so intentionally" (Shabbat 148b).
Rabbanit Marat Bruna's actions draw specific attention because they are unusual for her place and time. It seems from the titles given her and from the impression her religious practice made on others, that she had some status in the community. We can speculate that her elevated status in the community may have led her to seek out voluntary religious practice.
It is notable that Maharil's opposition to women fulfilling the mitzva of tzitzit contrasts with the ruling of Maharam, who preceded him as leader of Ashkenazi Jewry,
Tashbetz [Student of Maharam, in his master's name], 270
In any case, one should not protest their [women] wrapping themselves in tzitzit and reciting a beracha over it, for they can obligate themselves...
Maharam says that one should not protest a woman's fulfilling the mitzva of tzitzit. Yet Maharil opposes women’s observing the mitzva and refrains from protest only because he fears it will be counter-productive.
Why does Maharil oppose this practice? His responsum raises several arguments, but the concern for yuhara is the main one that gains prominence in halachic discussion:
New Responsa Maharil 7
It further seems to me that the mitzva of tzitzit is not like other mitzvot that are obligations incumbent on the individual. Rather, tzitzit, even though we consider it an obligation incumbent on the individual, applies specifically to one who has a four-cornered garment. But one is not obligated to purchase a four-cornered garment. Rather it is a mitzva to enter a situation in which one is obligated, as we learn with Moshe Rabbeinu: “Did he need to eat from its fruit?” [Moshe was praiseworthy in wishing to enter Israel – not because he wanted to enjoy its fruit, but in order to fulfill mitzvot that apply specifically there]. This applies to men. But women, why should they do this, since in the end they are not obligated…Even though I have seen women with four-cornered garments with tzitzit, and even today there is one in our neighborhood, it appears that they cause astonishment [at their behavior, viz. Menachot 40a] and it is considered spiritual conceit (yuhara) and they are called ignoramuses [hedyotot, viz. Yerushalmi Berachot 2:9 – “Whoever is exempt from something and nevertheless performs it is called a hedyot”].
A man is not obligated in tzitzit unless he dons a four-cornered garment. Already in Maharil's time, not all men fulfilled this mitzva regularly, because four-cornered garments were no longer standard clothing. Men wore a tallit katan as a special effort to fulfill the mitzva.
For a woman to go out of her way to don a tallit katan so that she can then go out of her way to attach tzitzit, while she is at no point commanded to do so, is one step too many for Maharil. He writes that such an act bespeaks yuhara, and is not allowed.
Rema's Ruling Rema opens his gloss in a way that seems to leave room for a woman to wear a garment with tzitzit and make a beracha over the mitzva. But he concludes by forbidding women from wearing tzitzit, based on concern for yuhara:
Rema, OC 17:2
Gloss: And still, if they want to wrap [tzitzit] and recite a beracha on it, they may do so, as with other positive time-bound commandments. But it looks like spiritual conceit (yuhara) and therefore they should not wear tzitzit, since it is not an obligation incumbent on the individual (meaning, the individual is not obligated to procure a shawl for himself in order to be obligated in tzitzit).
Rema's ruling here has found wide acceptance. Although at least one major subsequent Ashkenazi halachic authority omits Rema's view from his presentation of this halacha, that has not affected halachic discourse on this issue. Sefardi halachic decisors, such as Ben Ish Chai, have adopted Rema's ruling as well.
The Comparison to Sukka Why should a woman’s choosing to wear a garment with tzitzit be any different from her choosing to eat in a sukka throughout the holiday of Sukkot, which is accepted in Halacha?
Let's explain: Men are obligated to eat in the sukka on the first night of Sukkot. For the rest of the festival, they may not eat bread, or food over which the beracha “mezonot” is recited, outside of the sukka. But, aside from holiday and Shabbat meals, a man might theoretically avoid these foods and not eat in a sukka at all. On the other hand, some men make the extra effort to eat all food (even, say, a morning yogurt and coffee) in the sukka.
Women are exempt from the positive time-bound obligation to eat in the sukka. Yet there are women who are careful to eat bread and mezonot only in the sukka. Some women go out of their way to eat only in the sukka throughout Sukkot, even with foods like yogurt that are exempt for everyone. Why does no one denounce this as yuhara?
Aruch Ha-shulchan provides one possible response to this question:
Aruch Ha-shulchan 17:2
But really we never heard of this [of women wearing tzitzit] and we don't allow them to wear a tallit, and all the more so, to recite a beracha. It is not like shofar and sukka and lulav, which are once a year and the mitzva is done in an instant. Rather the mitzva of tzitzit is all year and it is not fitting for women.
According to Aruch Ha-shulchan, it is "not fitting" for a woman to take on an act that is meant to be performed on a daily basis voluntarily, perhaps because she is then implicitly claiming that she will be constant in maintaining her voluntary commitments, and making that type of a claim might itself be a sort of yuhara. While "the mitzva of tzitzit is all year," the possibility of eating in the sukka applies only one week a year and taking that mitzva on would be less ambitious or showy.
Aruch Ha-shulchan seems to assume that Halacha would require a woman who fulfills the mitzva of tzitzit some of the time, to take pains to fulfill it every time she wears a four-cornered garment. It is possible, however, that each act of wearing tzitzit could be seen as an isolated mitzva act, unless the woman chooses to take it on as a binding custom. (See more here.) In that case, Aruch Ha-shulchan's argument would be less persuasive.
However, even if we grant that a woman voluntarily wearing tzitzit need not intend to do so regularly, people could easily assume that she is making such a commitment. Perhaps just giving that impression would fall under Aruch Ha-Shulchan's definition of yuhara.
There is another significant difference between eating in a sukka and wearing tzitzit. Even a woman with no particular interest in fulfilling the mitzva of sukka will often join her family for meals there, because that is where the meal is being served. In this context, a woman who eats in the sukka out of intent to perform the mitzva can do so without concern for yuhara.
The analogy for tzitzit would be in Talmudic times, when husband and wife might have shared a garment, so that her wearing a four-cornered garment with tzitzit would not have raised concerns of yuhara. Once observing tzitzit entails both acquiring a four-cornered garment and affixing tzitzit, the concern for yuhara is stronger since the mitzva act is more demonstrative.
Why should a woman's motivations to wear tzitzit be questioned? Don't we praise chumra?
In our current religious climate, assumption of chumra (halachic stringency) has become an increasingly mainstream path for seeking religious meaning. If anything, someone taking on chumrot often receives praise for it. Perhaps in consequence, our sensitivities to the dangers of yuhara, whether in excess stringency or in disregard of traditional practice, have been dulled.
A woman looking to wear tzitzit may have difficulty relating to discussion of yuhara. She perceives her desire to wear tzitzit as a matter between herself and God, not other people. Especially if she normally wears shawls and scarfs to which she could affix tzitzit, she is not making an extra effort to put herself in a position in which she could voluntarily fulfil the mitzva.
However, an act that deviates from women's prevailing practice for hundreds and hundreds of years may be defined as yuhara even if we do not question an individual woman's motivation. It would likely take a large critical mass of women in supportive dialogue with rabbis for this to change.
The Scope of Yuhara
Three possible limitations on the applicability of yuhara might be relevant to our discussion of women and tzitzit: pious individuals, change over time, and acting in private.
I. Pious Individuals Unique individuals may prove exceptions to yuhara rules, and certain practices widely construed as yuhara are permitted to a great talmid chacham. For example, Maharil himself permits an exceptionally pious person to lay tefillin in the style of Rabbeinu Tam, even though he otherwise considers doing so to be an act of yuhara:
Responsa Maharil 137
Two pairs of tefillin—we have not seen the elders of our rabbis who acted thus…It seems that since it is not practiced it appears like yuhara. Only one whose piety is established and well-known should 'take on God's name.'
So too, perhaps it would not be considered yuhara for a woman known for extreme piety and stringency in Halacha to wear tzitzit, because it is consistent with her overall religious standing.
Historically, we have one report of a few, righteous thirteenth-century women in the area of Vienna, who fulfilled the mitzva of tztitzit:
Rav Avigdor Tzarfati, Sefer Peirushim Upsakim al Ha-Torah
Some righteous women were accustomed…to wrap themselves with tzitzit.
More recently, some notable female chassidic figures have worn tzitzit.
II. Change Over Time What is considered yuhara may change over time, as common practice changes. For example, holding tzitzit during recitation of Shema was once considered yuhara, but is now common practice.
Rav Aharon Lichtenstein suggests that this idea may apply to tzitzit for women.
Rav Aharon Lichtenstein, "The Human and Social Factor in Halakha"
It is not inconceivable that, at some point, fully responsible and fully committed gedolim will reexamine the Mahari Mullen's [Maharil's] position regarding women's wearing tzitzit.
Rav Lichtenstein asserts that yuhara is not an absolutely objective, timeless concept, and suggests that its application to women and tzitzit may evolve over time. At the same time, he leaves the determination of when times have changed to "gedolim," great rabbinic figures.
III. Yuhara in Private Whether or not yuhara applies in private settings is a matter of halachic debate.
In the sixteenth century, Rav Shlomo Luria argues that the very act of seeing oneself as "beyond" the community may constitute yuhara in any setting:
Yam Shel Shelomo, Bava Kama 7
Out of yuhara, which is to say that he shows himself as one who fears Heaven, but it is excessive pride…It is fitting to excommunicate a student who is haughty with Halacha—one who is stringent with a law when a permissive ruling has spread throughout all of Israel (even if he does not do it before his Rav)—if it is not known to the sage that the student certainly acted for the sake of Heaven. [In which case] even in public there would be no concern.
According to some opinions, one can avoid a yuhara concern by making a practice private. The common phrase "it appears like yuhara" suggests that we are concerned primarily with a public display of unusual piety. Rav Ya'akov Reischer, a major 18th century European halachic authority, teaches that, in private, yuhara is not a concern.
Responsa Shevut Ya'akov II:44
For specifically an individual who fears Heaven who wishes to be stringent with himself and act modestly is certainly remembered for good and has no yuhara…For certainly in private a person is permitted to be stringent with himself, which is not the case in public, for it appears like yuhara…Whoever does thus in private, his acts clearly show his intentions, that he does not do this out of yuhara.
To Rav Resicher, yuhara requires an audience. A person's private stringency is not yuhara, but a pious act known only to God.
Following this type of reasoning, Bach allows stringing tzitzit in an unusual way, which might normally be disallowed as yuhara, if it is worn under clothing:
Bach, End of Siman 11
Because it appears to be yuhara and the practice of 'those who cause astonishment' as Beit Yosef wrote, therefore he should not alter the tzitzit publicly on the tallit upon him to be different from common custom. But under his clothing that covers him, he can affix the tzitzit on the tallit katan in accordance with that view.
According to Bach, a tallit katan worn under clothing does not present the same yuhara concern as would a visible tallit.
Some modern-day halachic authorities permit a woman to fulfil the mitzva of tzitzit in private. Rav Yaakov Ariel has written that a tallit katan that is not seen would apparently not violate yuhara. So, too, Rav Eliezer Melamed permits a woman to wear a tallit gadol in private or a tallit katan in such a way that others cannot see it:
Peninei Halacha Likutim 1:8:8
Therefore, in my opinion, a woman who wants to wrap herself in tzitzit for God’s sake may do so in private. There is no concern for arrogance, and it is not an expression of resentment against halakha and the tradition. If many women do so for God’s sake and in private, then over time even if they wear tzitzit in a non-private setting it will not be considered arrogance or an offense against the traditions of the Torah. Nevertheless, in my opinion, even today one should not object to a woman whose intentions are for God’s sake and who wraps herself publicly in tzitzit, for she has authorities upon whom to rely. However, one should object to women who are not meticulous about many mitzvot but who specifically wear a talit publicly in order to express their opposition to halakhic tradition.
Rav Melamed relegates these comments to a footnote, an indication that he permits the practice, but does not freely advocate it. Nonetheless, he prints it. Rav Melamed adds two important points: that we should not protest against women who seek to fulfil the mitzva even in public, and that if more religiously-observant women come to wear tzitzit, the concern of yuhara may fade.
In a responsum on Jewish feminists, Rav Moshe Feinstein, a leading halachic authority of the twentieth century, relates directly to women wearing tzitzit:
Iggerot Moshe O.C. IV:49
…Indeed every woman is permitted to fulfill even mitzvot that the Torah did not obligate them [women] in, and it is considered a mitzva and [they receive] reward on fulfilling these mitzvot. Also, according to the position of the Tosafot, they are permitted to recite a beracha over the mitzvot like our custom that they fulfill the mitzva of shofar and lulav and also recite berachot. If this is so, even concerning tzitzit it applies to a woman who is willing to wear a garment that will be different from men's clothing but will have four corners, and to put tzitzit on it and fulfill this mitzva.…but it is obvious that that is only if her soul desires to fulfill mitzvot even when she is not commanded. However, if it is not done with this intention but rather out of protest against God and His Torah, this is not a mitzva act at all, but on the contrary a prohibited act …
Rav Feinstein associates women wearing tallit with the Conservative and Reform movements, which reject traditional understandings of Halacha, so he assumes that protest against Halacha will be a common motivation for a woman in a tallit. However, he allows that it would be permissible for a woman to don a distinctly female garment with tzitzit if her motivation were purely to fulfill the mitzva.
How should we relate to association of this issue with political statements or with denominational politics?
As Rav Moshe notes in his responsum, a woman's wearing of tzitzit, especially a full tallit, has come to be associated with non-Orthodox denominations and with protest against Halacha. Indeed, it is not easy to dissociate women wearing tzitzit from recent denominational history. Most significantly, this association seems to be what allows for unbridled protest in many rabbinic quarters.
When a woman who may not observe Shabbat wears tzitzit, there is strong concern for yuhara. Given that her overall religious practice is not in compliance with Halacha, it is more difficult to assume that she seeks to wear a garment with tzitzit without any intent to challenge traditional understandings of Halacha.
Making a statement through mitzva observance that seems to challenge the halachic order is unlikely to find rabbinic support.
On the other hand, if wearing tzitzit becomes more common among women who are Orthodox and careful to observe mitzvot in general, these associations could weaken over time.
In the late 1990s, Rav Zalman Nechemya Goldberg, a leading halachic decisor, penned an article on women and tzitzit as part of the discussion regarding Women of the Wall, a women's tefilla group at the Kotel with members who wear tallit. Toward the end of the article, he writes:
Rav Zalman Nechemya Goldberg, "Women's Prayer in Public (Response)"
We have in hand enough mitzvot and good deeds that one can direct women to fulfill…If after all this their souls yearn specifically for the mitzva of tzitzit, perhaps there is room for them to go about with a tallit katan under their clothing. But there is room for this, only after they excel in all that in which they are obligated. Even if they do this, it should be done in private.
A tallit gadol worn in public is associated with political and religious controversy. However, Rav Goldberg acknowledges the potential to permit a woman to wear tzitzit in a private fashion if it fits her overall spiritual and halachic attainments. That stipulation, coupled with his reluctant tone, indicates that his concerns transcend a more technical definition of yuhara.
In many Orthodox communities, this entire discussion is beyond the pale. Most halachically observant women do not wear tzitzit, and the rulings to permit it are reluctant. Both Rav Feinstein and Rav Goldberg are concerned with the possible political motivations of a woman in a tallit. For them, the technical aspects of yuhara (like the technical aspects of keli gever) are surmountable, but the spirit of yuhara (and keli gever) remains in question.
Nevertheless, rulings like those by Rav Feinstein and Rav Goldberg leave room for a woman to fulfil mitzvat tzitzit in a private way (and with a feminine garment).
Why is interest in fulfilling the mitzva of tzitzit comparatively rare in the Orthodox community?
While some religiously-observant women may be interested in tzitzit, the majority are not. Why is this the case, especially when tzitzit is such a significant and beautiful mitzva?
The lack of interest most likely reflects deference to tradition, and to the mainstream halachic opinions discouraging women from wearing tzitzit.
Other factors might also be at play, though: An instinctive feeling that tzitzit is for men. Or that wearing tzitzit is a provocation. Or that it would add bulk to a woman's look. Or that constructing a female set of tzitzit would take a lot of know-how and effort. Or that tzitzit should be worn every day, and that would be daunting to take on.
The Lubavitcher Rebbe suggested that women fulfill positive time-bound mitzvot through their husbands. Indeed, many women have a strong relationship to tzitzit, through the men in the family: whether ducking under a father's tallit as a child and playing with the strings, buying one for a fiancé and standing under it at the chuppa, or thrilling as a bar mitzva boy wraps himself in a tallit for the first time.
Though, depending on her life circumstances, a woman may find some of these experiences resonate less with her, they do come from a world of Jewish women past and present. Some exceptional women have worn tzitzit. Still, for many women, the relationship with the mitzva will remain powerful, positive, and indirect in the foreseeable future.
 Berachot 17b
Since everyone performs labor [on the ninth of Av], but he does not perform it, it appears like spiritual haughtiness.
 See Responsa Maharil 137, quoted below.
 Yedidya Alter Dinari, "Chochmei Ashkenaz Be-Shilhei Yemei Ha-beinayim." (Jerusalem: Mossad Bialik, 1984), 32. See also Responsa Maharil 94 and 124.
 Responsa of Rav Natronai Ga'on (Brody ed.), O.C. 6
Thus said Rav Natronai: You asked: when a person recites Keri'at Shema, does he need to hold his four tzitzit or not? This practice is not the way of the sages or students. It is the way of excess [yetirut]. Once he has contemplated his tzitzit at the time of his wrapping and recited a beracha over them, afterwards, why should he hold them in his hand?
The word "yetirut," excess, is quoted in Kol Bo (and Abudarham) as "yehiruta," which is "yuhara."
Abudarham, laws of Keri'at Shema
But Rav Natronai wrote that one who holds his tzitzit in his hand when he recites Keri'at Shema is acting with yehirut…
Beit Yosef OC 24 cites Abudarham.
 Responsa Mahari Bruna 96
I was asked about the young men who wear a tallit katan over their clothes in public and say that it suits them to fulfil a mitzva in public, are we concerned for yuhara or not? I responded that everything goes according to the time and custom and person. At first glance, it seems to me that one should be concerned.
Available here: http://hebrewbooks.org/pdfpager.aspx?req=42821&st=&pgnum=82.
 Beit Yosef O.C. 11
Our Great Rabbi Mahari Abuhab wrote….'The way of tzitzit is that we should make two holes in the tallit and place the tzitzit inside them and take them out to one side [of the cloth]…If I were not afraid, I would say that he can put on all of these tzitzit, as one master maintains, and as another master maintains, and he can make a condition that if one is fit, the other are as nothing [to him], and in this manner it would not be bal tosif (adding on to the mitzvot). This requires study.' We have never seen anyone who is concerned for this matter at all…One who is stringent upon himself in this way appears to be spiritually haughty.
 Maharil also argues that voluntary mitzva performance is out of place when it may conflict with another halachic obligation Specifically, he raises concerns that a woman might come to wear tzitzit made from kil'ayim (which is only permissible to someone obligated in the mitzva) or might come to carry on Shabbat.
 Beit Yosef OC 17 cites this position, but does not rule accordingly in Shulchan Aruch.
Shulchan Aruch OC 17
Women and bondsmen are exempt, for it is a positive time-bound commandment.
 Chayyei Adam I:11:43
Women are exempt from tzitzit, because it is a positive time-bound commandment, for night is not a time of tzitzit. In any case, if they want to wear and recite a beracha, they may recite a beracha. This is the law for every positive time-bound mitzva.
 Ben Ish Chai, Lech Lecha 13
Even though we maintain with shofar and sukka and the like that if they [women] wanted to fulfil [them] they may do so and they receive reward like someone who is not commanded but performs, and there is no concern of 'whoever is exempt from a matter and does it is called a simpleton,' still, in this mitzva it appears like yuhara.
 Rav Yosef Engel (Atvan d'Orayta 11) goes so far as to claim that the voluntary aspect of the man's performance means that the Torah's desire is not for the wearing of tzitzit, but to prohibit four-cornered garments from being worn if tzitzit are missing. Since tzitzit cannot be said to be "missing" from a four cornered garment worn by a woman, her wearing tzitzit has no meaning.
Rav Yosef Engel, Atvan d'Orayta 11
That women are not permitted to recite a beracha over tzitzit, because it is not a positive mitzva but a negative one, that there not be a lack of tzitzit for the garment.
Bach argues that when a mitzva act is not customary, we defer to stringent opinions prohibiting a voluntary performer from reciting a beracha. For this reason, a woman fulfilling mitzvat tzitzit should not recite a beracha.
If a woman came to ask beforehand if it is permissible for her to wear tzitzit and to recite a beracha, they should tell her not to recite a beracha, because it is better that they [women] not recite a beracha in an area of rabbinic debate.
 Levush implies that an argument like this may apply to Michal, daughter of King Shaul:
Levush OC 17:2
But in any case it appears like silliness and yuhara if they [women] do thus [wear tzitzit]. Since it is only a man's obligation, what connection do they have to this mitzva?...Even though in other positive time-bound commandments like sukka and lulav, they are accustomed to perform it and recite a beracha over it, what is practiced is practiced, and what is not practiced should not be practiced. With tzitzit, we have not found that they [women] practiced it except for one in a thousand, like Michal daughter of Shaul and those like her, and therefore they [women] should not wrap themselves [in a tallit].
 Quoted, Avraham Grossman, Ve-hu Yimshol Bach, Jerusalem: Merkaz Zalman Shazar, 2010, p. 318.
 Ada Rappaport-Albert, "Al Ha-nashim Be-chasidut," in Tzadik Va-eida: Hebetim Historiyim Ve-chevratiyim Be-cheker Ha-chasidut, ed. David Assaf (Jerusalem: Merkaz Zalman Shazar, 2001), 507.
 Beit Yosef OC 24
Now that some people practice it [kissing tzitzit during the recitation of Shema], it no longer appears like yuhara.
 Rav Aharon Lichtenstein, "The Human and Social Factor in Halakha," in Leaves of Faith, Vol. I (Jersey City: Ktav, 2003), 182.
 Rav Ya'akov Ariel, "May Women Wear Tzitzit?"
With a tallit katan that is not seen, it would seem there is no yuhara.
Available here: http://www.yeshiva.org.il/ask/?srch=1&orderby=&q=%D7%A0%D7%A9%D7%99%D7%9D+%D7%98%D7%9C%D7%99%D7%AA&cat=1
 Rav Zalman Nechemya Goldberg, "Tefillat Nashim Be-farhesya (Response)." Tehumin 18 (1998): 122.