drafted or revised to use must, may, will or should. Unfortunately, without knowledgeable legal guidance, eliminating shall altogether in existing documents and templates will require an examination of innumerable documents and a close analysis each time the word shall appears in a document to find the correct meaning and replace it with the appropriate word. Alternatively, global corrective language can be inserted in existing documents to require that all uses of the word shall are interpreted as imperative and not permissive.NotesBryan Garner, Legal Writing in Plain English, at 125-128 (2001).Gutierrez de Martinez v. Lamagno, 515 U.S. 417 (1995).Seeid. See, e.g., Bryan Garner, Legal Writing in Plain English, at 125-128 (2001) (citing West Wis, Ry, v. Foley, 94 U.S. 100, 103 (1877); Gutierrez de Martinez v Lamagno, 515 U.S. 417, 434 (1877) (adding that "certain of the Federal Rules use the word 'shall' to authorize, but not require, judicial action," citing Fed. R. Civ. P. 16(e) and Fed. R. Crim. P. 11(b)). See, e.g., Bryan Garner, Legal Writing in Plain English, at 125-128 (2001) (citing Railroad Co. v. Hetch, 95 U.S. 168, 170 (1877); Scott v. United States, 436 U.S. 128, 146 (1978) (Brennan, J., dissenting); United States v. Montalvo-Murillo, 495 U.S. 711, 712 (1990). Fed. R. Evid. 1 advisory committee's note; Fed. R. Civ. P. 1 advisory committee's note ("The restyled rules minimize the use of inherently ambiguous words. For example, the word "shall" can mean "must," "may," or something else, depending on context. The potential for confusion is exacerbated by the fact that "shall" is no longer generally used in spoken or clearly written English. The restyled rules replace "shall" with "must," "may," or "should," depending on which one the context and established interpretation make correct in each rule.").Id. The Federal Plain Writing Act of 2010, Pub. L. 111–274 (2010). The Plain Language Action and Information Network, Federal Plain Language Guidelines (May 2011).Id. Office of the