It is usually recognized that lawbreaking, if it is not done publicly, at least must be publicly announced in order to constitute civil disobedience. But Stephen Eilmann argues that if it is necessary to disobey rules that conflict with morality, we might ask why disobedience should take the form of public civil disobedience rather than simply covert lawbreaking. If a lawyer wishes to help a client overcome legal obstacles to securing her or his natural rights, he might, for instance, find that assisting in fabricating evidence or committing perjury is more effective than open disobedience. This assumes that common morality does not have a prohibition on deceit in such situations. The Fully Informed Jury Association's publication "A Primer for Prospective Jurors" notes, "Think of the dilemma faced by German citizens when Hitler's secret police demanded to know if they were hiding a Jew in their house." By this definition, civil disobedience could be traced back to the Book of Exodus, where Shiphrah and Puah refused a direct order of Pharaoh but misrepresented how they did it. (Exodus 1: 15-19)