Lithuania Changed the Testimony
The Genocide Center printed the 1980 sentence. Lithuania's defense of Jonas Noreika says the name arrived fifteen years later.
On September 25, 2018, Vytautas Landsbergis, who chaired Lithuania's Supreme Council during the restoration of independence, published a defense of Jonas Noreika on the website of the Homeland Union-Lithuanian Christian Democrats. He conceded that Aleksandras Pakalniškis's 1980 memoir Plungė contains a Lithuanian commandant saying that he had already ordered the Jews shot. Landsbergis's answer was that the speaker was unnamed and therefore would have been Povilas Alimas; only in the 1995 version, he wrote, did Noreika's surname appear in that passage.[1]
Landsbergis returned to the argument in Naujasis Židinys-Aidai in 2021. Writing of the later edition, he stated: “Šis taip eksploatuojamas vardas atsiranda antroje Pakalniškio atsiminimų versijoje (Per dvidešimtąjį amžių, 1995).” This so-exploited name appears in the second version of Pakalniškis's memoirs. A few lines later he wrote: “Noreika atsiranda po 15 metų, ir tai jau literatūra.” Noreika appears after fifteen years, and that is already literature.[2]
Two years before Landsbergis's 2018 defense, Alfredas Rukšėnas, a historian at Lithuania's Genocide and Resistance Research Center, had printed the relevant passage from the 1980 book in Genocidas ir rezistencija, then the Center's own journal. The sentence says the opposite.[3]
The sentence was already there
“O Plungę tuo tarpu valdė lietuvių karininkų grupelė su komendantu kapitonu Noreika viršūnėje.”[4]
“Meanwhile, Plungė was ruled by a small group of Lithuanian officers, with commandant Captain Noreika at the top.”
The narrative then moves into the commandant's office. A German soldier asks what will be done with the Jews. “The commandant” answers that he has already ordered them all shot. Pakalniškis's 1980 text does not repeat the surname inside the dialogue. It has already identified the commandant immediately before the dialogue. Rukšėnas then writes: “Kaip matyti, 1980 m. atsiminimuose komendanto, kuris davė įsakymą sušaudyti aukas, pavardė nenurodoma.” My translation: “As can be seen, in the 1980 memoir the surname of the commandant who gave the order to shoot the victims is not indicated.”[5]
At the end of June 1941, Jews of Plungė were arrested and confined in two synagogues. Roughly two weeks later, men, women and children were taken to Kaušėnai and shot. The Center's October 2015 finding gives approximately 1,800 victims and dates the principal killing to July 15-16; Rukšėnas's 2016 article gives about 2,000 victims and dates the killing to July 12-13. The Center could interrogate Pakalniškis's chronology while its own publications used different dates. None of that makes the words “commandant Captain Noreika” disappear from the 1980 sentence.[6]
Andrius Kulikauskas, who conducted the underlying historical research for my submissions concerning Noreika, cites Aleksandras Pakalniškis's Plungė (Chicago, 1980), pp. 46-49. The same passage is independently reproduced by Genocide Center historian Alfredas Rukšėnas in the Center's own journal.[7]
What changed in 1995
The 1995 memoir, Per dvidešimtąjį amžių, is more explicit. Pakalniškis again says Captain Noreika was commandant, says he worked for several days in the commandant's office, and then repeats Noreika's name inside the reported exchange. The Genocide Center printed that passage in its own 2015 English finding.[8]
That is new specificity. It is not a new surname. The 1980 sequence is: Captain Noreika is identified as commandant; the commandant gives the order. The 1995 sequence repeats Noreika's name within the dialogue itself. A historian is entitled to ask why a later memoir became more explicit. A historian is not entitled to convert additional specificity into the proposition that the earlier book contained no Noreika name.
Rukšėnas's sentence has two readings. Confined to the dialogue, it is true: Pakalniškis does not repeat the surname inside the quoted exchange. Read as it is written about the 1980 memoir, it is false, because the surname is indicated in the sentence before the dialogue, on the same printed page Rukšėnas transcribed. In 2018 Landsbergis conceded that the dialogue existed but wrote that the unnamed speaker would have been Alimas and that Noreika's surname appeared in the 1995 text. In 2021 he wrote that the “so-exploited name” appears in the second version and that “Noreika appears after fifteen years.”[9]
Landsbergis also claimed that executioners' surnames present in the earlier version were omitted from the later book and pointed to Pakalniškis's anti-Jewish language. Those comparison claims should be tested against both books, and Pakalniškis's anti-Jewish assumptions require no defense from me. Neither changes the sentence Rukšėnas transcribed from 1980: “commandant Captain Noreika.”
Pakalniškis gave the defense real evidence against him
Pakalniškis was a difficult witness. In a 1984 interview with Akiračiai, reproduced years later by Noreika defender Vidmantas Valiušaitis, he admitted that he had not known Noreika personally, had never spoken with him, did not recognize Jonas Noreika from a photograph, and knew only the surname, not even whether the man was named Jonas. He nevertheless maintained that he worked beside the commandant's room and heard the exchange. Those admissions come to us through the defense's own reproduction.[10]
That evidence creates a genuine identity problem: did the Captain Noreika whom Pakalniškis described mean Jonas Noreika-General Vėtra? It does not create a textual problem. The 1980 memoir names a Captain Noreika. The weakness of the witness cannot be converted into absence of the word.
The Center had already placed Noreika in the office
The Center's October 2015 finding says there was information that Jonas Noreika worked in the Lithuanian commandant's office in Plungė. It attributes that information to priest Povilas Pukys, interrogated on August 4, 1945. According to the Center's own summary, the office was initially led by an unnamed military officer with the rank of captain; two days later Povilas Alimas took the position. The finding then says that in July 1941 Noreika had official relationships with both the Telšiai LAF and the Plungė commandant structure.[11]
The same document nevertheless relied on six postwar witnesses, “especially” Pukys, to conclude that Noreika had “never been the commandant of Plungė City.” Pukys did not give the Center that clean sequence. He supplied an unnamed captain, then Alimas, and evidence placing Noreika in the office.[12]
Rukšėnas, writing after the 2015 finding, identified the unnamed captain as Stanislovas Lipčius. He did not pretend Pukys had identified the man as Noreika; he expressly said Pukys had not. His Lipčius identification rests on a 1946 interrogation of Kostas Raudonis and a 1951 review of criminal cases.[13]
Lipčius may be the correct identification. The evidentiary asymmetry remains. Soviet interrogation and criminal-case material was sufficient to install Lipčius in the gap, sufficient to establish Alimas as commandant, and useful when the Center noted that Noreika's Soviet indictment did not accuse him of killing people. Pakalniškis's signed American memoir was subjected to destructive comparison across editions, titles, dates and command structures. Soviet provenance was not disqualifying when it helped the defense.[14]
The Center adopted the answer
This did not remain a dispute between one memoirist and one historian. On July 18, 2018, the Genocide Center issued Letter No. 14R-52 in response to the 69-page historical inquiry I had submitted with supporting research. Item 13 quoted the 1980 proposition almost verbatim: Plungė was controlled by Lithuanian officers with commandant Noreika at the top. The Center answered that it had already supplied its reasoned view explaining why Pakalniškis's statement was wrong. Its authority was Rukšėnas's 2016 article.[15]
Item 24 confronted the Pukys evidence that Noreika worked in the commandant's office alongside Alimas. Again the Center directed the reader to Rukšėnas for the reasons it refused to regard Noreika as commandant, participant, initiator or organizer of the Kaušėnai massacre.[16]
The Center published its response on its own website the next day under the title Dėl informacijos pateikimo. It published the answer without the underlying submission. The response therefore became the public state version of the dispute while the questions and evidence it was answering were not presented beside it.[17]
When the answer went to court
I challenged Letter No. 14R-52 in the Vilnius administrative courts. The Center's October 1, 2018 defense argued that its letter was purely informational, created no legal consequences, was not an individual legal act, and therefore could not itself be the object of an administrative dispute. At the same time, the Center defended the substance of the letter as the product of historical methodology and said the material I had submitted supplied no basis for changing its Noreika conclusion.[18]
The litigation was later renumbered Administrative Case No. eI-534-281/2019, while trial No. 3-61-3-02757-2018-5 remained the same. The Vilnius District Administrative Court rejected the complaint in March 2019. On April 1, 2020, the Supreme Administrative Court left the first-instance result in place and held that my 2018 approach did not concern Center activity classified as public administration; the demand to annul the response was therefore not examinable under the administrative-court procedure. The state could publish an official historical answer, rely on it in public controversy, and then place the dispute outside the route by which an administrative act is reviewed.[19]
The identity defense eventually became unnecessary
The Center also argued that Noreika could not have ordered the Plungė Jews shot “at his own initiative” because Lithuanian personnel involved in mass killing were subordinated to German security police and SD officers. Rukšėnas made the point even more plainly: Pakalniškis's version would still be wrong if the commandant giving the order had been Alimas, because Lithuanian commandants did not possess autonomous authority to organize such operations.[20]
That reasoning answers a different proposition. Pakalniškis reported an officer saying he had given an order. An officer implementing German policy can transmit a superior order and direct subordinates without possessing sovereign authority to originate extermination policy. The German chain of command does not prove that no Lithuanian officer could have spoken the words Pakalniškis attributed to the commandant.
I developed the wider commandant, Soviet-source and German-authority problems in How Lithuania Discredited Its Witness. The narrower prosecution here is textual: the state's own scholarship preserves a 1980 sentence that the later public defense says was not there.[21]
The witness the Center trusted drew a different map
The 2015 finding used Damijonas Riauka's recollections to support Noreika's anti-Nazi image, citing postwar periodical accounts from Ūkininkas and Trimitas. In August 2026, Silvia Foti published another object Riauka had given her in 2013 as evidence for the defense: a commemorative chart of the 1941 uprising. On it, the Žemaitija structure runs across six districts beneath the notation “Vadas kpt. Jonas Noreika” - Commander, Captain Jonas Noreika.[22]
Foti does not present the chart as a contemporaneous 1941 operational document, and neither do I. Its value here is narrower. The exculpatory witness whom the Center accepted as useful evidence himself memorialized Noreika as a regional commander. That evidence should face the same source criticism imposed on Pakalniškis. See The Defense's Last Witness Drew the Map.[23]
The finding is what the state kept
By February 2020 the Center had been put on direct notice again. Through attorney Rokas Rudzinskas, I demanded annulment of the Noreika findings. The Center refused. Its February 11 response described the 2015, 2017, March 2019 and December 2019 texts as the product of “integral and comprehensive research” that “constitute a whole.” It specifically denied that Pakalniškis had been rejected merely because the earlier edition did not directly name Jonas Noreika in the commandant dialogue; it invoked the wider body of testimony, documents and research.[24]
That wider defense does not answer the sentence. Rukšėnas printed “commandant Captain Noreika” from the 1980 book. The Center then used Rukšėnas as its official answer when confronted with that sentence. Landsbergis wrote in 2018 that Noreika's surname appeared in the 1995 passage; in 2021 he wrote that the “so-exploited name” appears in the second version and that “Noreika appears after fifteen years.”
As of August 2026, the findings stand. The October 2015 memorandum has not been withdrawn. The December 17, 2019 memorandum written by Dalius Stančikas, presenting Noreika as a rescuer of Jews, has not been withdrawn; Stančikas was not a historian. The Center refused annulment on February 11, 2020, refused again in its final reply of February 20, 2020, and in March 2022 declined to reopen the matter. No correction of these findings has been issued.[25]
The Genocide Center printed the 1980 words “commandant Captain Noreika” in 2016. As of August 2026, the findings that reject Pakalniškis's account still stand.
[1] Vytautas Landsbergis, ‘Šis tas nauja dėl „Generolo Vėtros“,’ TS-LKD, September 25, 2018. Landsbergis concedes that the 1980 memoir contains a Lithuanian commandant saying he had already ordered the Jews shot, but argues that the unnamed speaker would have been Povilas Alimas and that the 1995 version introduced Noreika’s surname into the passage. https://tsajunga.lt/aktualijos/sis-tas-nauja-del-generolo-vetros/ . The same text is preserved in fixed print form in Vytautas Landsbergis, Teisė ir neteisė (Vilnius: TS-LKD, 2018), 88.
[2] Vytautas Landsbergis, ‘Istoriografijos džiunglėse,’ Naujasis Židinys-Aidai, no. 8 (2021), 8-9. Landsbergis writes: ‘Šis taip eksploatuojamas vardas atsiranda antroje Pakalniškio atsiminimų versijoje (Per dvidešimtąjį amžių, 1995)’ and ‘Noreika atsiranda po 15 metų, ir tai jau literatūra.’ Issue PDF: https://nzidinys.lt/wp-content/uploads/2022/05/NZ-A-2021-Nr-8-PRENUMERATA-3.pdf ; article page: https://nzidinys.lt/vytautas-landsbergis-istoriografijos-dziunglese-nz-a-nr-8/ . The same passage also says that executioners’ surnames and Pakalniškis’s open antisemitism present in the earlier version were omitted or absent from the later version; those are separate comparison claims from the timing of the Noreika name.
[3] Alfredas Rukšėnas, ‘Jono Noreikos-Generolo Vėtros biografijos kontroversijos,’ Genocidas ir rezistencija 1, no. 39 (2016): 39-64, published May 30, 2016, DOI 10.61903/GR.2016.102. The journal was published by the LGGRTC when Rukšėnas's article appeared in 2016 and is now hosted on the Vilnius University journals platform. Vilnius University journal metadata: https://www.journals.vu.lt/gr/article/view/35731 ; Center-hosted issue PDF: https://www.genocid.lt/UserFiles/File/leidyba/Zurnalas/39_zurnalas.pdf
[4] Aleksandras Pakalniškis, Plungė (Chicago: M. Morkūno spaustuvė, 1980), 48-49, quoted by Rukšėnas, ‘Jono Noreikos-Generolo Vėtros biografijos kontroversijos,’ 54. Rukšėnas’s transcription reads: ‘O Plungę tuo tarpu valdė lietuvių karininkų grupelė su komendantu kapitonu Noreika viršūnėje.’
[5] Rukšėnas, ‘Jono Noreikos-Generolo Vėtros biografijos kontroversijos,’ printed journal p. 54. Immediately after reproducing the 1980 passage naming ‘commandant Captain Noreika,’ he writes: ‘Kaip matyti, 1980 m. atsiminimuose komendanto, kuris davė įsakymą sušaudyti aukas, pavardė nenurodoma.’ Translation: ‘As can be seen, in the 1980 memoir the surname of the commandant who gave the order to shoot the victims is not indicated.’ Confined to the quoted dialogue, that observation is true; read as written of the memoir, it conflicts with the surname printed immediately before the dialogue on the same page. Center-hosted issue PDF: https://www.genocid.lt/UserFiles/File/leidyba/Zurnalas/39_zurnalas.pdf ; Vilnius University metadata: https://www.journals.vu.lt/gr/article/view/35731
[6] Genocide and Resistance Research Center of Lithuania, Activity of Jonas Noreika (General Vėtra) in Nazi-Occupied Lithuania, October 2015, 2, signed by Director General Teresė Birutė Burauskaitė; Rukšėnas, ‘Jono Noreikos-Generolo Vėtros biografijos kontroversijos,’ 54. Rukšėnas states that Plungė Jews were arrested at the end of June and held in two synagogues, and gives about 2,000 victims killed at Kaušėnai on July 12-13; the 2015 finding gives approximately 1,800 victims and July 15-16 while also reproducing Pakalniškis’s July 12-13 account. English finding: https://static-cdn.toi-media.com/blogs/uploads/2026/05/noreika-memorandum-2015-EN-Genocide-Center.pdf ; Lithuanian original: https://static-cdn.toi-media.com/blogs/uploads/2026/05/201510_noreika_pazyma01.pdf ; Rukšėnas issue PDF: https://www.genocid.lt/UserFiles/File/leidyba/Zurnalas/39_zurnalas.pdf
[7] Andrius Kulikauskas, 'Jonas Noreika šaltiniai,' ms.lt, citing Aleksandras Pakalniškis, Plungė (Chicago, 1980), pp. 46-49 for the role of Noreika, officers, and the military in the murder of the Jews: https://www.ms.lt/sodas/Mintys/JonasNoreika%C5%A0altiniai. The same passage is transcribed by Rukšėnas at printed journal p. 54. Bibliographic identifiers for the volume include LCCN 92200390 and LC classification DK505.95.P58 P35 1980.
[8] Aleksandras Pakalniškis, Per dvidešimtąjį amžių (Chicago, 1995), 119, quoted in Genocide Center, Activity of Jonas Noreika, 2. The Center’s English text identifies ‘Lithuanian kommandant captain Noreika’ as the speaker. https://static-cdn.toi-media.com/blogs/uploads/2026/05/noreika-memorandum-2015-EN-Genocide-Center.pdf
[9] Rukšėnas, printed journal p. 54, writes that in the 1980 memoir the surname of the commandant who gave the shooting order ‘is not indicated.’ The text he has just transcribed identifies ‘commandant Captain Noreika’ immediately before the dialogue. Compare Vytautas Landsbergis, ‘Šis tas nauja dėl „Generolo Vėtros“,’ TS-LKD, September 25, 2018, https://tsajunga.lt/aktualijos/sis-tas-nauja-del-generolo-vetros/ , and Landsbergis, ‘Istoriografijos džiunglėse,’ Naujasis Židinys-Aidai, no. 8 (2021), 8-9, https://nzidinys.lt/wp-content/uploads/2022/05/NZ-A-2021-Nr-8-PRENUMERATA-3.pdf . The sequence is documented; no claim is made here that Landsbergis derived his formulation from Rukšėnas.
[10] Vidmantas Valiušaitis, ‘General Storm: what is the worth of the Pakalniškis attestation about Noreika?,’ Lithuania Tribune, May 21, 2019, reproducing the 1984 Akiračiai interview ‘Apie žudynes Plungėje,’ no. 7 (161). Pakalniškis said he did not know Noreika personally, had never spoken with him, did not recognize the photograph, and knew only the surname. https://lithuaniatribune.com/general-storm-vetra/
[11] Genocide Center, Activity of Jonas Noreika, 1. Pukys’s August 4, 1945 interrogation is cited there as LYA, f. K-1, ap. 58, b. 34851/3, l. 15 a.p.-16. The finding states that an unknown captain initially led the office, that Alimas took the position two days later, and that Noreika had official relationships with the Telšiai LAF and the Plungė commandant structure.
[12] Ibid., 2. The six witnesses named are Zenonas Rudavičius, Jonas Buivydas, Jonas Šližius, Zigmas Daržinskas, Leonas Laurinavičius and Povilas Pukys. The finding says their evidence, ‘especially’ Pukys’s, supports the conclusion that Noreika had ‘never been the commandant of Plungė City.’
[13] Rukšėnas, ‘Jono Noreikos-Generolo Vėtros biografijos kontroversijos,’ printed journal p. 45, nn. 38-39. On p. 45, Rukšėnas states that Pukys did not equate Noreika with the captain who held the commandant post for two days before Alimas and identifies the unnamed officer as Captain Lipčius. Note 38 cites Pukys; note 39 cites the Soviet-era material used for the Lipčius identification, including the 1946 interrogation of Kostas Raudonis and the 1951 criminal-case review. This citation uses the article’s printed journal pagination, not a PDF viewer page count. Center-hosted issue PDF: https://www.genocid.lt/UserFiles/File/leidyba/Zurnalas/39_zurnalas.pdf
[14] Rukšėnas, 45, 55; Genocide Center, Activity of Jonas Noreika, 2-4. Rukšėnas uses Soviet-era material to identify Lipčius at p. 45 and relies on postwar criminal-case evidence in rejecting Pakalniškis at p. 55. The Center likewise relies on Soviet criminal files to establish Alimas and other actors and later notes that Noreika’s Soviet indictment and judgment did not accuse him of killing people. The argument here concerns consistency of source criticism, not a claim that Soviet-era testimony is inherently false.
[15] Lietuvos gyventojų genocido ir rezistencijos tyrimo centras, Letter No. 14R-52, July 18, 2018, item 13, response to Grant Arthur Gochin. Grantgochin copy: https://grantgochin.com/wp-content/uploads/2018/08/genocide-center-noreika-response-7-18-18.pdf ; Lithuanian original: https://static-cdn.toi-media.com/blogs/uploads/2026/05/20180719_noreika.pdf . Item 13 quotes the Pakalniškis sentence placing ‘commandant Noreika’ at the top and directs the reader to Rukšėnas’s 2016 article for the Center’s reasoned view that the statement is incorrect.
[16] LGGRTC Letter No. 14R-52, July 18, 2018, item 24. The submission quoted Pukys to the effect that Noreika worked in the commandant’s office with Alimas; the Center again cited Rukšėnas for its reasons for not regarding Noreika as commandant, participant, initiator or organizer of the Kaušėnai killings. Same links as note 15.
[17] LGGRTC, ‘Dėl informacijos pateikimo,’ published July 19, 2018. Center page: https://www.genocid.lt/centras/lt/2969/a/ ; 2018 archive listing: https://www.genocid.lt/centras/lt/3042/a/print_version/ ; preserved copy: https://static-cdn.toi-media.com/blogs/uploads/2026/05/Regarding-the-provision-of-information.pdf
[18] LGGRTC defendant response, October 1, 2018, Administrative Case No. eI-4215-281/2018, paras. 48-53, arguing that Letter No. 14R-52 was purely informational, produced no legal consequences, was not an individual legal act and could not be the object of an administrative dispute. The same litigation was subsequently numbered eI-534-281/2019; trial No. 3-61-3-02757-2018-5 remained unchanged. https://grantgochin.com/wp-content/uploads/2018/10/lt-govt-defense.pdf ; archival copy: https://static-cdn.toi-media.com/blogs/uploads/2026/05/lt-govt-defense.pdf
[19] The same proceeding was originally identified as Administrative Case No. eI-4215-281/2018 and was later numbered eI-534-281/2019; trial No. 3-61-3-02757-2018-5 remained the same. Vilnius District Administrative Court, decision of March 27, 2019, Case No. eI-534-281/2019; Lithuanian Supreme Administrative Court, Case No. eA-1768-624/2020, April 1, 2020. The Supreme Administrative Court held that the 2018 approach did not concern Center activity classified as public administration and that the demand to annul the response was not examinable under administrative-court procedure. Official LVAT summary: https://www.lvat.lt/galutine-ir-neskundziama-nutartimi-issprestas-gincas-del-lietuvos-gyventoju-genocido-ir-rezistencijos-tyrimo-centro-rasto-panaikinimo/834 ; first-instance English translation: https://static-cdn.toi-media.com/blogs/uploads/2026/04/Vilnius_County_administartive_court_2019-03-27sprendimas-bylojeeI-534-281-2019_gv.pdf
[20] Genocide Center, Activity of Jonas Noreika, 2: ‘J. Noreika could not order to shoot Plungė Jews ... at his own initiative.’ Rukšėnas, ‘Jono Noreikos-Generolo Vėtros biografijos kontroversijos,’ printed journal p. 55, states that Pakalniškis’s version would still be incorrect even if the commandant giving the order were Povilas Alimas, because the historical literature did not support autonomous Lithuanian-commandant authority to organize mass-killing operations. This citation uses the article’s printed journal pagination. Center-hosted issue PDF: https://www.genocid.lt/UserFiles/File/leidyba/Zurnalas/39_zurnalas.pdf
[21] Grant Arthur Gochin, ‘How Lithuania Discredited Its Witness,’ Substack, May 21, 2026. https://grantgochin.substack.com/p/how-lithuania-discredited-its-witness
[22] Genocide Center, Activity of Jonas Noreika, 4, citing Damijonas Riauka material in Ūkininkas no. 51 (February 1994) and Trimitas no. 3 (March 1996). Silvia Foti, ‘The Defense’s Last Witness Drew the Map,’ Times of Israel Blogs, August 9, 2026. https://blogs.timesofisrael.com/the-defenses-last-witness-drew-the-map/
[23] Foti, ‘The Defense’s Last Witness Drew the Map.’ Foti describes a commemorative chart given to her by Riauka in 2013; she treats it as a later commemorative reconstruction, not a contemporaneous 1941 operational record. https://blogs.timesofisrael.com/the-defenses-last-witness-drew-the-map/
[24] Genocide and Resistance Research Center of Lithuania, ‘On the Provision of Information,’ February 11, 2020, response to the January 16, 2020 demand. The Center says the relevant findings are the result of integral and comprehensive research and ‘constitute a whole,’ and rejects the claim that Pakalniškis was dismissed solely because the earlier edition did not directly name Jonas Noreika in the commandant dialogue. English: https://static-cdn.toi-media.com/blogs/uploads/2026/05/Atsakymas-Gochinui-i-01-16_en.pdf ; Lithuanian: https://static-cdn.toi-media.com/blogs/uploads/2026/05/Atsakymas-Gochinui-i-01-16.pdf
[25] December 17, 2019 Stančikas memorandum; February 11, 2020 refusal to annul; February 20, 2020 final reply No. 14R-14; March 2022 response declining to reopen.