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The Sefer Minchas Mechareshes says that Rashi means to say that the Parsha was said by Hashem for Moshe to write down not before the second year, even according to the opinion that the Yisro came before Mattan Torah, because it concludes (18:27) with an event that only happened after the second month of the second year. Note that Rashi holds (Shemos 24:7) ...


I think "the second year" is counting the year as starting from Tishrei. Thus, the Yom Kippur of "the second year" is the first Yom Kippur after leaving Egypt. Rashi thus means to say that these events occurred about four months before the Giving of the Torah, which is written later.

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