In a recent post at Lawyerist.com, “Thy Legal Writing Shall Not Include ‘Shall’“, Andy Mergendahl examines the overuse (and misuse) of “shall” in legal writing. After attending a Bryan Garner legal writing workshop, Mergendahl discovered his intense dislike of the use of “shall” and suggests alternatives to its use in legal writing. Mergendahl writes: “‘Shall,’ due to its multiple meanings, creates ambiguity that greatly increases the likelihood of disputes about what a sentence means. That is exactly what we are paid to avoid.” True. Very true.