WilmerHale

WilmerHale (Wilmer Cutler Pickering Hale and Dorr LLP) is an American law firm formed in 2004 by the merger of the Boston firm Hale and Dorr and the Washington firm Wilmer Cutler Pickering. Its partner John J. Butts defended JPMorgan Chase in Government of the United States Virgin Islands v. JPMorgan Chase Bank, the 2022 to 2023 suit over the bank's banking of Jeffrey Epstein, including over a 2008 decision on Epstein's accounts attributed to the bank's general counsel, Stephen Cutler, a former WilmerHale partner and former enforcement director of the Securities and Exchange Commission. The firm also reviewed Epstein-related conduct for Apollo Global Management in 2021 and for the trustees of Bard College in 2026. Robert Mueller was a partner of Hale and Dorr from 1993 to 1995 and of WilmerHale from 2014 to 2017, before and after his service as special counsel.¹²³

Mueller

The firm announced on March 24, 2014 that Mueller was joining as a partner after twelve years as Director of the Federal Bureau of Investigation, a post he took one week before the September 11 attacks. Co-managing partner Robert Novick said that he brought "his broad range of experience as a career prosecutor, an ability to lead the most sensitive investigations, his steady hand in a crisis and unquestioned integrity." Mueller left in 2017 on his appointment as special counsel for the investigation of Russian interference in the 2016 presidential election, and the firm announced his return as a partner in October 2019. He said: "I'm glad to be at WilmerHale once again, a firm with a tradition of honoring public service."¹²

Cutler

Cutler was Director of the SEC's Division of Enforcement from October 2001 to May 2005, a period in which the division brought the Enron-related action that JPMorgan Chase settled for 135 million dollars in July 2003. He joined WilmerHale in October 2005 as a partner and co-chair of its Securities Department. On December 12, 2006 JPMorgan Chase announced that he would become its Executive Vice President and General Counsel from February 2007, reporting to chief executive Jamie Dimon.⁴⁵

The Virgin Islands Suit

The Government of the United States Virgin Islands sued JPMorgan on December 27, 2022 before Judge Jed Rakoff in the U.S. District Court for the Southern District of New York. On May 28, 2023, near the close of discovery, JPMorgan produced a 22-page summary from an internal review begun after Epstein's 2019 arrest and code-named "Project Jeep." On June 7, 2023 the territory's counsel, Motley Rice, asked Rakoff to reopen depositions, citing emails showing that the former Bear Stearns chairman Alan Greenberg had gone to Cutler "for an exception to the felony policy" for Epstein and a 2008 email stating that "JPM requires top of the house ok for clients who are convicted felons. (ie PCS Legal to Asset Mgt Legal to Cutler to Jaime Daimnon [sic])."³⁶

Butts answered for the bank on June 9, 2023 that the summary was compiled after Epstein's death by employees with "no contemporaneous knowledge" of the relationship, that 216 of its 222 underlying emails had been produced months earlier, that Dimon had testified he did not recognize the name "Project Jeep" and had instructed the general counsel to "do everything" to establish the facts, that the author of a 2019 email had confirmed "top of house" there meant then general counsel Stacey Friedman, and that a follow-up sent eight minutes after the 2008 email showed that "top of the house" referred to Cutler. The letter stated that after Epstein's 2008 plea "people from legacy Bear Stearns, including Mr. Greenberg, in connection with post-acquisition transition of accounts, may have attempted to speak with Stephen Cutler, then JPMC's General Counsel, about application of JPMC's corporate policy requiring approval of its General Counsel ... to retain a brokerage account for a client with a felony conviction," that the decision "was made by Mr. Cutler," and that there was "no evidence that Mr. Greenberg had anything to do with Epstein's accounts at the Private Bank." In August 2023 Rakoff declined to compel production of all Project Jeep materials. JPMorgan settled with the territory on September 26, 2023 for 75 million dollars without admitting wrongdoing.³⁷

Apollo and Bard

On January 25, 2021, the day the Dechert review of Leon Black's 158 million dollars in payments to Epstein was released, Black told Apollo's limited partners that he would retire as chief executive and disclosed that Apollo had engaged WilmerHale to review its reputational-risk and corporate-citizenship practices.⁸

After the Justice Department's releases under the Epstein Files Transparency Act, Bard's trustees retained the firm in February 2026 to review the communications and financial dealings of the college's president, Leon Botstein, with Epstein. Its summary of April 30, 2026 recorded 25 visits by Botstein to Epstein's Manhattan townhouse between 2012 and 2019 and a two-day visit to the island, reported that Epstein twice visited Bard "accompanied by multiple women who have since been identified as victims of Epstein," and quoted Botstein: "I would take money from Satan if it permitted me to do God's work." It concluded that he "did not do anything illegal," but that he "minimized and was not fully accurate in describing his relationship with Epstein." His retirement was announced the next day.⁹

OpenAI

On December 8, 2023 the special committee of the OpenAI board, Bret Taylor and Larry Summers, selected Anjan Sahni and Hallie B. Levin of WilmerHale to review the November 17, 2023 removal of Sam Altman and Greg Brockman. The summary released on March 8, 2024 found that the prior board's decision "did not arise out of concerns regarding product safety or security, the pace of development, OpenAI's finances, or its statements to investors, customers, or business partners," and that Altman's "conduct did not mandate removal."¹⁰