"When in doubt whether to produce a document, your decision should almost always be to disclose the document," the manual states. "It is better to overproduce than underproduce. If you have a question whether or not to produce a document, speak to your supervisor. If you are leaning towards a belief that the rules don't require you to produce a document, picture yourself explaining your position in front of the judge and make sure you are on solid ground under the rules to not produce a document. Don't play semantic games in an attempt not to produce a document."