The Behavior of the French Army During the Dreyfus Affair

By   /   February 18, 2013 


29 Touro Law Review 17

The Behavior of the French Army During the Dreyfus Affair

General André Bach*


At the outset, it must be made clear that you cannot lump together, or reduce to monolithic groups, the army, judges, public officials, and “intellectuals” as though their members could only think and behave in lock-step uniformity.  Such a precaution needs to be taken even more carefully when dealing with the army, an institution where speaking out officially in public is strictly regulated.1  The army, or at least some of its members, figured significantly in the Dreyfus affair in its three successive parts: the incident of espionage, the legal case, and lastly, the political ramifications.

Based on the results of my research in the military archives, my topic will be to examine how the high command of the French army behaved in the course of these three periods.


I.          Espionage

We must not forget that the origin of the entire affaire was a case of espionage, a fact that has never been called into doubt.2  How it was discovered and conducted weighs significantly in the errors that marred the legal phase.

At this point in my research, my thesis, which can be challenged, is that from the beginning there was an effort at disinformation carried out from the highest French political and military echelons to distract the attention of the German military attaché in Paris from the top-secret improvement of a cannon prototype; its cutting-edge technology was considered a likely critical asset in any eventual armed confrontation with Germany.3  In order to do this, a corrupt officer, Major Esterhazy, who possessed certain credible but non-vital information, was manipulated to make contact with the attaché and hold out to him the prospect of gaining access to numerous secret documents.4  This type of contact is always very perilous for a military attaché, whose official function does not involve spying.  There is always a risk of dealing with a pawn (someone who is being manipulated) or with a set-up.  To dispel such doubt and protect the attaché, I believe, without having any formal proof of this, that the bordereau (note) must have been a document penned in a handwriting imitating Esterhazy’s, forged by the French service in charge of security at German embassies, and slipped, somewhat torn, into the attaché’s wastebasket.  This wastebasket, emptied by a French employee, was an ideal receptacle in which to transmit information to the enemy.5

Seen from the German side, such a practice had to allow for any doubt to be dispelled about the nature of this enigmatic spy, the bearer of secrets that his military position did not make him privy to.  If they heard subsequently that Esterhazy had been arrested, it would certainly confirm that the discarded papers in the wastebasket were getting to the French counter-espionage department, but first and foremost, they would know where things stood.  Esterhazy being arrested, and thus exposed, would mean that Esterhazy was not being manipulated by the opposing departments.  The loss of this source of information would not be a loss at all, because it could turn out that he was only an intermediary; the next task would be to approach the “deep throat” who was furnishing information from high-ranking sources without wishing to become known.6  If he were not arrested, contact with him would have to be broken off, because it would mean being caught up in an attempt at disinformationAll this merely exemplifies the ordinary thought processes in milieu routinely immersed in this kind of government activity.

Much to the Germans’ surprise, a third unexpected scenario ensued.7  It was not Esterhazy who was arrested, but another officer, Captain Dreyfus, unknown to the German departments.8

On October 27, 1916, in the midst of the Battle of Verdun, during a dinner for General Petain in Souilly, France, M. Hanotaux, minister of foreign affairs at the time Dreyfus was charged, evoked these secret dealings, the source of the judicial error, by justifying them: “This affair revolved around the hydraulic brake.  It’s an interesting question since it was kept secret until the war.  It’s what made the 75 mm model superior to the German 77 mm model.”9  Thus, the atmosphere is one of dirty tricks.

When these tricks, carried out in secrecy, go awry, they create innocent victims or result solely in the conviction of minor, low-level players; the responsible parties are rarely affected, since the powers-that-be realize that revealing the truth would be harmful, either to the government or to important figures.10  Every nation will thereby hide the reality of a dirty trick, and will deny it, to protect the higher interests of the government.  Once such a denial is proclaimed, it is obvious that the innocence of the person, caught up by mistake in a mechanism beyond his control and incomprehensible to him, does not weigh heavily in the equation: an individual’s interests are subordinate to those of the nation.  Concealing acts like these is easy to accomplish because they took place clandestinely.  Clearing the name of the innocent party would require revealing the deception, which was totally out of the question in the international sphere.


II.        Who were the military leaders who thrust Dreyfus into this affair?

First, Dreyfus was the victim of the French counter-espionage department.11  This bureau had only risen to prominence through the will of General Boulanger, the Minister of War at the time.12  This department, reorganized in 1886, was charged with tracking down, investigating, and prosecuting those guilty of violating the law of April 18, 1886.13  Grown too big, too fast, this organization, which in its new format was only eight years old in 1894, was characterized by the mediocrity of its staff.14  Its head, Commander Sandherr, suffered a mental collapse just as the Dreyfus affair was beginning and was provisionally replaced by his assistant, Major Henry.15  Even today we can only be surprised to see a boor of this sort in such a delicate position; he may have been well trained in basic police methods, but was completely unsuited for his office.16  We would say today that he was completely miscast for his role.17  In this particular case, all Henry did was send off the bordereau, according to protocol, to his superiors at the War Ministry.18

Second, Dreyfus was the victim of anti-Semitism from the officers in the Army General Staff.19  These officers were greatly composed of young, middle-class men who, while at the officers’ school, had been exposed to the ideology of the landed aristocracy and were greatly influenced by anti-Semitic sentiments fed by prejudices stemming from their family and professional backgrounds.20

Like the mostly Catholic milieu they came from, they had integrated into their world-view the implicit or explicit opprobrium disseminated by the Church toward the Jews.21  In addition, for the German-speaking officers from Alsace, particularly well represented in espionage and counter-espionage (Sandherr, Picquart, Lauth, Junck, Fritsch, etc.), Alsatian anti-Semitism (similar to its German variety), formed part of their world-view.22  Moreover, the conquest of Algeria and Tunisia had, for decades, put quite a few officers in contact with Sephardic communities there.23  Having made the strategic choice to win over the Arab tribes, French officers widely adopted the past prejudices of these tribes.24  Thus, it comes as no surprise that when a spy was sought among the recently commissioned officers of the General Staff, suspicion immediately fell upon the only officer who was Jewish.25  Nevertheless, we must avoid generalization and over-simplification.  During Dreyfus’s two-year apprenticeship, that is to say four six-month stints in the four different bureaus at headquarters, he had only aroused suspicion in one of them—the one responsible for the mobilization of the army and troop movement to the borders.26  He had been praised for zeal and competence in the other three bureaus.27

In a certain way, Dreyfus was the victim of the reform put into place by General de Miribel, chief of the General Staff.28  This reform had been established so that the recruitment would no longer be carried out through co-option, but rather through merit, as determined by class rankings bestowed at the École de Guerre.29  Co-option, with its unwritten rules, had the advantage of functioning discretely.30  At the end of the nineteenth century, one of the unwritten rules in all European armies was to prohibit access to positions of command to Jews.31

No better proof of this could be found than in the subtle handwritten note sent to the chief of personnel by the same General de Miribel, the author of the reform that gave Dreyfus, ranked twelfth in his class at the École de Guerre, automatic entry to a high level of the general staff.32  This very short note remains in General Valabrègue’s personnel file to this very day and it states: “22 January, 1891.  General de Miribel has given the order to the chief of the personnel department at headquarters not to accept Major Valabrègue to a post at the general staff.”33  Major Valabrègue, a “brilliant officer,” second in his class at the École de Guerre in 1880, given consistently high mention thereafter, was born into the Jewish community in the region of Avignon, France.34

In 1892, as a result of the reform, it became impossible to send such a note about new promotions, since rank at the École de Guerre was now the deciding factor.35  On the other hand, in cases of suspected disloyalty, for certain officers on the general staff, there was no need to look any further if a Jew had been associated with those bureaus.36  This attitude explains why Captain d’Aboville of the fourth bureau immediately suggested Dreyfus’s name—and only his name.37  The fact that Dreyfus’s handwriting style was very typical at the time served to justify the immediate initial suspicion lodged against him.38


III.       The Legal Case

At this point we enter into the legal case with the Minister of War, General Mercier, playing a leading role in the unfolding drama.

At the dinner for Pétain in October 1916, Hanotaux recalls:

When I saw the Affaire taken on by General Mercier, I went myself to the Ministry to find him, I told him that he was going to plunge the Army and FRANCE into a difficult crisis, that he must wait before ordering the arrest [of Dreyfus] at his home, that he must send DREYFUS to the provinces where he could be monitored and caught red-handed, which was Impossible in PARIS.  The general let me speak.  He pulled out his watch and replied: “Too late—the arrest has already been carried out.  General MERCIER was inept, he has made a grave mistake; probably because of his ambition.  DRUMONT was pressuring him . . . .”39

General Saussier, the commander-in-chief, whom I suspect is the source of the disinformation and the manipulation of Major Esterhazy through the intermediary of his agent Maurice Weill, had then declared to the President of the Republic, Casimir-Périer: “Dreyfus is not guilty.  That fool Mercier has put his finger in his own eye again!”40

In the trial, we cannot fault the code of Military Justice, but can fault certain irregularities, mainly the handing over of documents by Mercier, unbeknownst to the lawyer, and the pressure put on the military judges by the swaggering Henry, who, calling it his duty and assured of being backed up by the hierarchy, used his position and rank to impress the judges.41


IV.       The Political Affair

With Dreyfus in prison, the stage was set for the political affair.  Once the decision was made to refuse to reexamine the Dreyfus case—not because of anti-Semitism, but in order to avoid a reprise of the political disorders—the anti-Semitic factor became less important for high-ranking politicians and military leaders.42

There are several distinct phases in this process, set in motion by Picquart’s revelations.43  The French Government, along with Premier Méline, quickly understood how reopening the Dreyfus case could destabilize the country.44  France’s Minister of War, very distrustful and suspicious of the General Staff, urged the General Staff to set up the ridiculous masquerade with the thought that by protecting Esterhazy, they might protect the General Staff.45  General de Boisdeffre paid a professional price when his glibness on the subject was discovered.46

The expression of the truth was also blocked by a burst of irrationality; the only explanation for the inexplicable relentlessness of two former officers of the Fourth Bureau, one of whom had become Cavaignac’s principal private secretary, General Roget, and his other aide-de-camp, Captain Cuignet.47  Cuignet, a veritable fanatic, redrafted the entire secret indictment file in order to prevent the review of the case, reclassifying the hodge-podge of its three-hundred genuine and falsified documents, and adding a tendentious commentary intended to throw off the track judges not familiar with military practices.48  His activism at the time of the Rennes trial became so unbearable that he was dismissed from the army.49  This did not prevent him from continuing to vituperate once he became affiliated with Action Française.50

At the Rennes trial, the issue was not to find out whether Dreyfus was innocent or guilty, but whether the Republic, as it was then functioning, could resist the challenge of the protests going on in the streets.51  A battle between the opportunists and the radicals had been raging between the years 1894 and 1899; recurrence of high street violence by extreme right-wing groups and extreme left-wing groups with their anarchist tendencies was greatly feared.52  For the high command in solidarity with those in power, charged with maintaining order in the country, Dreyfus’s personal situation became less important.53  Whether he was guilty or innocent no longer held any interest—the aim was to stabilize the political and social situation.54

The first conclusion is that Dreyfus’s fate depended on the machinations of a handful of individuals, for the most part military leaders at the top rung of the hierarchy.


V.        And What About the Army as a Constituent Body?

In a period when the army was adapting slowly to the Republic but very badly to parliamentary government, the challenge to hierarchy coagulated thinking.  As Armand Charpentier accurately observes: “The question, for them, was no longer to know whether the bordereau was Esterhazy’s or Dreyfus’s, but rather to defend the major leaders representing the army against Dreyfus, who had become a symbolic entity behind which were grouped together Jews, intellectuals, revolutionaries, all the so-called enemies of the army.”55  The course of events only served to reinforce this attitude, with the majority heeding the cries of Action Française—the army’s self-proclaimed defender.56  The minority, who were expressing doubts, had no choice but to keep their feelings quiet or leave the army.57

The idea that a process of destabilization of the army was operative was only strengthened in the years afterward when the army, where many officers were graduates of parochial schools, had to take part in the obligatory opening up of Catholic religious institutions.58  At the same time, the discovery that their promotion was henceforth controlled by political power, informed by secret files, and drafted by Freemason organizations caused a widening sense of victimization.59  They did not grasp that these emergency measures stemmed from fear of the political sphere—the specter of collusion between the army and right-wing rioters to bring down the regime—which had perceived the absence of the republican feeling in its corporatist spirit.60

Déroulède’s exhortation, made on February 27, 1899, to General Roget to rally his troops behind his supporters at President Faure’s funeral and to march on Élysée Palace, coupled with the lack of response by the military security service when the president of the republic had been manhandled in Auteuil on June 4, 1899, explain a tightening of political power and not a desire to dismantle the army.61  However, in the community of the officers corps, formed in the analysis of events according to the binary concept of friend-or-foe, the officers saw in this tight political surveillance of their institution the action of a vague, many-faceted and hateful enemy: the Dreyfusards, an ill-defined group, who were suspected of being fundamentally anti-military and—an even more slanderous suspicion—anti-patriotic, a grave insult at the time.62

They saw the denunciation of military behavior, such as the conduct of the Military Justice during the First World War, for example, or the practice of torture in Algeria, as the actions of the heirs of those who had challenged the authority of the army’s 1894 “final verdict” on Dreyfus.63  It was not a leap for them to target this line of descent since the protesters proclaimed themselves to be the upholders and spiritual heirs of these very Dreyfusards, as in the case of the late Pierre Vidal-Naquet.64

Thus Dreyfus’s name, even today, remains connected to tense and dark periods in the history of the army and, therefore, remains a subject no one wants to broach in the officers’ club.65  However, the army considers him one of its own, a victim of a judicial crime due to the scheming of General Mercier, and one who, all through his long ordeal, showed mental strength as well as civic and moral qualities worth holding up as examples to young generations of officers.66



* General André Bach had a classic military career in the French army between 1965 and 2000, mainly as a paratrooper.  He participated in several missions, including one in 1985-1986 with a battalion of United Nations peacekeepers in Southern Lebanon.  During this period of service, he also held various positions in communications, education, and historical research.  A graduate of the Institut d’Études Politiques in Paris, he was the head of Le Cours Histoire et Stratégie militaire at l’École de Guerre and, for three years, Le Service Historique de l’Armée de Terre au château de Vincennes—which houses military archives, including the “secret file” used to convict Captain Dreyfus.  General Bach is a specialist in the history of the Third Republic, in particular the period of World War I.  He is the author of L’ArmÉe de Dreyfus, Une histoire politique de l’armée française de Charles X à “l’Affaire” (Tallandier 2004).  It is this book that inspired Pierre Vidal-Naquet to comment “From this point on, the affair, while not ceasing to be absurd, becomes intelligible.”  The Touro Law Review thanks Cheryl Weisberg for her excellent translation of this article from French to English.



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  1. See Piers Paul Read, The Dreyfus Affair: The Scandal that Tore France in Two 51 (2012) (“After its humiliating defeat in the Franco-Prussian war, the French Army had been reorganised along the lines of its German counterpart which had so emphatically demonstrated its superiority in the field.  Conscription was introduced and the High Command was divided into four departments, or bureaux.”).
  2. See id. at 52 (discussing French anxiety over espionage).
  3. Id. at 59-61.
  4. Émile Zola, The Dreyfus Affair: “J’accuse” and Other Writings 180 (Alain Pagès ed., Eleanor Levieux trans., Yale Univ. Press 1996).
  5. Read, supra note 1, at 59.
  6. See Mark Feldstein, Who Is Deep Throat? Does It Matter?, Am. J. Rev. (Aug./Sept. 2004), (discussing the term “deep throat”).
  7. See Zola, supra note 4, at 179 (explaining that it was Alfred Dreyfus who was arrested).
  8. Nicholas Halasz, Five Years of my Life: The Diary of Captain Alfred Dreyfus 19-21 (1977); see also Zola, supra note 4, at 179-80.
  9. Document Conservé Archives École Supérieure de Guerre, École Militaire Paris: Entretien Pétain-Hanotaux (Oct. 27, 1916) [Interview with Pétain Hanotaux, War College, École Militaire Paris (Oct. 27, 1916)] (a reproduced excerpt of this conversation is on file with the Touro Law Review); see also Germany: 7.7cm Feldkanone 96 n.A, Landships, (last visited Nov. 4, 2012) (“The Germans had just started to distribute the FK C/96 to the troops, when the French introduced their famous ‘75,’ a gun that revolutionized gun design forever.  And over-night the French gun made the technically new German C/96 completely obsolete.”).
  10. See Third Republic 1892-1906 – The Dreyfus Affair,, (last modified Nov. 7, 2011) (stating that authorities—backed by parliament—refused to reopen the Dreyfus case even after having received a letter denouncing Major Esterhazy as the Bordereau’s true author).
  11. Général André Bach, L’ArmÉe de Dreyfus 549-56 (2004).
  12. Third Republic 1886-1889 – The Boulanger Affair,, (last modified Nov. 7, 2011).
  13. Les Enseignements du Capitaine Alfred Dreyfus, Conseil ReprÉsentatif des Institutions Juives de France (July 19, 2011), [hereinafter Les Enseignements]; see also Leslie Derfler, The Dreyfus Affair 1 (Linda S. Frey & Marsha L. Frey eds., 2002).
  14. Les Enseignements, supra note 13.
  15. Id.
  16. Id.
  17. Id.
  18. Derfler, supra note 13.
  19. Bach, supra note 11, at 529-38; see also Les Enseignements, supra note 13; Steven Lubet, Why the Dreyfus Affair Does and Doesn’t Matter, 13 Green Bag 2d 329, 330 (2010) (reviewing Louis Begley, Why the Dreyfus Affair Matters (Yale Univ. Press 2009)) (distinguishing the Dreyfus Affair from the Rosenbergs).
  20. Les Enseignements, supra note 13; see also Derfler, supra note 13, at 7.
  21. Les Enseignements, supra note 13; see also Derfler, supra note 13, at 129.
  22. Les Enseignements, supra note 13; see also Derfler, supra note 13, at 40, 129.
  23. Les Enseignements, supra  note 13; see also Derfler, supra note 13, at 129 (discussing the riots which took place in Algeria, as well as in many other major Jewish communities).
  24. Les Enseignements, supra note 13; see also Derfler, supra note 13, at 129.
  25. Alfred Dreyfus and “The Affair,” Jewish Virtual Libr., (last visited Sept. 20, 2012).
  26. Les Enseignements, supra note 13.
  27. Id.
  28. Id.
  29. Id.
  30. Id.
  31. Les Enseignements, supra note 13.
  32. Id.
  33. Dossier du Personnel du Général Valabrègue (conservé au Service Historique) [Personnel file of General Valabrègue (preserved in the History Department)].
  34. Les Enseignements, supra note 13.
  35. Id.
  36. Id.; see also Lubet, supra note 19, at 329-32 (stating that Dreyfus was targeted solely because of his Jewish origin).
  37. Les Enseignements, supra note 13; see also Maurice PalÉologue, My Secret Diary of the Dreyfus Case 1894-1899 16 (Eric Mosbacher trans., 1957) (stating the proposition that whoever was responsible for writing the bordereau had to be part of the General Staff and had to be an artilleryman); Derfler, supra note 13, at 118 (noting that Dreyfus’s “unpopularity and Jewish origins accounted for a presumption of guilt”); Louis Begley, Why the Dreyfus Affair Matters (2009), as reprinted in (observing that Dreyfus was singled out due to his racial background); Lubet, supra note 19, at 331 (explaining that suspicion fell on Dreyfus because he was the only member of the General Staff who was Jewish).
  38. See Begley, supra note 37 (explaining that although Dreyfus’s handwriting was similar to that on the bordereau, “slanted, highly cursive script was [being] taught at every school,” and therefore it should not have came as a surprise); Lubet, supra note 19, at 331 (noting that several graphologists were unable to agree on whether or not it was Dreyfus’s handwriting on the bordereau, but nevertheless, his Jewish origins made him an easy target).
  39. Document Conservé Archives École Supérieure de Guerre, École Militaire Paris: Entretien Pétain-Hanotaux (Oct. 21, 1916) [Interview with Pétain Hanotaux, War College, École Militaire Paris (Oct. 21, 1916)].  Drumont refers to Edouard Drumont, an anti-Semitic journalist and writer who wrote La France Juive—a two-volume book on Jews in France—and founded La Libre Parole, “a daily journal of rabid anti-Semitic tendencies.”  Drumont, Edouard Adolphe, Jewish Encyclopedia, (last visited Nov. 14, 2012); see also Les Enseignements, supra note 13; PalÉologue, supra note 37, at 12 (showing Hanotaux’s declaration: “If you have no evidence other than this letter and a resemblance of handwriting, I am opposed to any judicial proceedings, and even to any inquiry.  The national interest is at stake”); Brief History of the Affair, The Univ. of Pa. Libr., (last visited Sept. 25, 2012) (stating that General Mercier fabricated documents in order to incriminate Dreyfus).
  40. PalÉologue, supra note 37, at 33.
  41. See Derfler, supra note 13, at 89-90; Brief History of the Affair, supra note 39 (stating that Mercier “furnished judges with a ‘secret file’ of fabricated documents, not seen by the defense, which incriminated Dreyfus”).
  42. See David L. Lewis, Prisoners of Honor: The Dreyfus Affair 147-48 (1973) (explaining that reopening the Dreyfus case would ruin the reputation of France’s “most important officers”).
  43. Id. at 143; see also Third Republic 1892-1906, supra note 10; Brief History of the Affair, supra note 39.
  44. Nicholas Halasz, Captain Dreyfus: The Story of a Mass Hysteria 106 (1955).
  45. Id. at 99-100; see also John Ehrman, The Dreyfus Affair: Enduring CI Lessons, 55 Stud. Intelligence 21, 24 (2011), available at (stating that the officers from the General Staff “conspired directly with Esterházy to forge more documents to add to the case against Dreyfus”); Lubet, supra note 19, at 332 (discussing how the French military chose to protect Esterhazy instead of liberating Dreyfus).
  46. See Halasz, supra note 44, at 177 (stating that “Boisdeffre was replaced by General Renouard”); Zola, supra note 4, at 194 (showing that Colonel Henry was arrested after admitting to having committed forgery and General de Boisdeffre consequently requested that he be relieved of all his duties).
  47. Halasz, supra note 44, at 173-74; see also Read, supra note 1, at 244, 246, 252.
  48. Jacques Kayser, The Dreyfus Affair 275-76 (Nora Bickley trans., 2010) (1931).
  49. Jean-Denis Bredin, The Affair: The Case of Alfred Dreyfus 381 (Jeffrey Mehlman trans., George Braziller, Inc. 1986) (1983).
  50. See Robert L. Hoffman, More than a Trial: The Struggle Over Captain Dreyfus 33 (1980) (describing the Action Française); Read, supra note 1, at 337 (labeling Captain Cuignet as “a recent convert to anti-Dreyfusism”).
  51. See Bredin, supra note 49, at 285-86 (describing what occurred in the streets).
  52. Id. at 285-86, 288; see also Lewis, supra note 42, at 251 (describing the fear of another Commune); Betty Schechter, The Dreyfus Affair: A National Scandal 135 (1965) (“Where did the greater danger to France lie—in facing the demands of democracy or in denying them?”); Hoffman, supra note 50, at 188 (describing the two camps that were formed as a result of the Dreyfus affair).
  53. See Schechter, supra note 52, at 134-35 (describing what the Dreyfus case evolved into); Hoffman, supra note 50, at 187 (“Alfred Dreyfus was no longer the principal focal point for contention, but France remained divided and at war with itself.”).
  54. Bredin, supra note 49, at 296.
  55. Armand Charpentier, Les Côtés Mystérieux de L’Affaire Dreyfus 319 (1937).
  56. The Condemnation of the “Action Française” 8 (Leo Ward ed., 1928).
  57. Michael R. Marrus, The Politics of Assimilation: A Study of the French Jewish Community at the Time of the Dreyfus Affair 212 (1971).
  58. Piers Paul Read, The Dreyfus Affair: The Story of the Most Infamous Miscarriage of Justice in French History 30, 263 (2012).
  59. Bredin, supra note 49, at 113.
  60. See H.R. Kedward, The Dreyfus Affair: Catalyst for Tensions in French Society 43 (1965) (“[T]he Affair [was] only an incident in the democracy and the counter-revolution.  While the power of the army remain[ed,] the Revolution [was] unfinished.  Monarchists and Catholics [were] using the army in their plot against the Republic.”); Stephen Wilson, Ideology and Experience: Antisemitism in France at the Time of the Dreyfus Affair 433 (1982) (describing the “class struggle” between the right-wing rioters and the “Extreme Left”).
  61. Frederick Brown, For the Soul of France: Culture Wars in the Age of Dreyfus 220 (2010); see also Bredin, supra note 49, at 385 (describing the attempted attack on the president).
  62. Brown, supra note 61, at 177, 196.
  63. Bredin, supra note 49, at 540-41.
  64. Id. at 531; 20 Encylcopaedia Judaica 516-17 (Fred Skolnik et al. eds., 2d ed. 2007).
  65. See Kayser, supra note 48, at 361 (issuing the order that “[t]he incident is closed!”).
  66. Bredin, supra note 49, at 356.