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The Biur Halacha in Mishna Berura Siman 25 seems to say clearly that as long as it's in front of you, even if not specifically being held in your hand, it would still require tefillin first. So putting down the shel rosh shouldn't make a difference, since in most cases both the shel yad and the shel rosh are together in their own bag/case that would mean ...


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