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---
category: "Private Organization"
tags:
- Organization
- DarkMoney
- JudicialCrisisNetwork
- ConcordFund
- LeonardLeo
- FederalistSociety
- MarbleFreedomTrust
- WellspringCommittee
- SupremeCourt
- Section501c4
alias:
- Judicial Crisis Network
- JCN
- Concord Fund
- The Concord Fund
- Judicial Confirmation Network
summary: "Virginia 501(c)(4) incorporated in December 2004 as the Judicial Confirmation Network, which ran advertising for Supreme Court nominations on anonymous donations and Marble Freedom Trust grants until its termination on January 6, 2026."
start: 2004-12
end: 2026-01-06
location: "Vienna, Virginia"
relations:
- type: head_of
with: "[[Gary Marx]]"
reverse: true
start: 2005
role: "president in 2005; president, secretary, treasurer and director in the returns for June 2019 and June 2025"
fn: 1
- type: head_of
with: "[[Daniel L. Casey]]"
reverse: true
end: 2019-11-19
role: "president and director"
fn: 13
- type: head_of
with: "[[Carrie Severino]]"
reverse: true
role: "president in the returns for June 2021 and June 2022; counsel from the return for June 2023"
fn: 3
- type: employed_by
with: "[[Ann Corkery]]"
reverse: true
role: "counsel, 256,063 dollars in the return for June 2021 and 395,655 dollars in the return for June 2025"
fn: 3
- type: employed_by
with: "[[Neil Corkery]]"
reverse: true
start: 2005
role: "treasurer in 2005; custodian of records in 2008"
fn: 1
- type: funded
with: "[[Wellspring Committee]]"
reverse: true
role: "principal donor; one anonymous donor gave Wellspring 28.5 million dollars in 2016, per press reports of its return"
fn: 8
- type: funded
with: "[[Marble Freedom Trust]]"
reverse: true
role: "grants of 16.5, 28.9, 55.5, 60.45 and 33.45 million dollars in the five fiscal years ended April 30, 2021 to 2025"
fn: 18
- type: contractor_to
with: "[[CRC Advisors]]"
reverse: true
role: "consulting, 7,679,331 dollars in the June 2021 return and 4,610,996 dollars in the June 2025 return; as CRC Public Relations at the same address in the returns for 2016 to 2019"
fn: 15
- type: contractor_to
with: "[[Mentzer Media]]"
reverse: true
role: "advertising, 12,322,297 dollars in the return for June 2019"
fn: 15
- type: funded
with: "[[Lexington Fund]]"
role: "grant of 200,000 dollars in the return for June 2025"
fn: 19
- type: funded
with: "[[Republican Attorneys General Association]]"
role: "grants of 1, 4, 2 and 1.5 million dollars in the returns for June 2022 to June 2025"
fn: 19
created: 2026-10-01
updated: 2026-10-01
---
The Judicial Crisis Network was incorporated in December 2004 as the Judicial Confirmation Network, a [[Virginia]] organization exempt under section 501(c)(4) of the [[Internal Revenue Code]] with the employer identification number 20-2303252. It ran television advertising for and against nominations to the [[Supreme Court of the United States]] and, in its later returns, made grants of millions of dollars to political committees. Its returns record contributions of 827,106 dollars for calendar 2005 and, for the fiscal years ended June, 18,545,000 dollars in 2016, 48,134,887 dollars in 2021 and 65,100,191 dollars in 2024, without naming donors. The Concord Fund, the name it carried in its last returns, filed articles of termination with Virginia on January 6, 2026.[^1][^2][^3][^4]
### Incorporation and First Return
The return for the calendar year 2005, filed by the Judicial Confirmation Network from 9502 Nelson Lane, [[Manassas, Virginia]], stated: "The Judicial Confirmation Network was incorporated in December 2004. During 2005, the Organization applied to the [[Internal Revenue Service]] for tax-exempt status under section 501 (c) (4)." Its purpose was "to support the confirmation of highly qualified individuals to the Supreme Court of the [[United States]]" and to ensure that "every nominee sent to the full [[United States Senate]] receives an up or down vote." Revenue was 827,106 dollars and expenses 772,820 dollars. The officers were [[Gary Marx]], president, paid 60,000 dollars; [[Neil Corkery]], treasurer, paid 16,000 dollars, at the Nelson Lane address; and [[James Hirsen]], secretary, unpaid.[^1]
On June 13, 2007 the [[Mitt Romney]] presidential campaign announced a National Faith and Values Steering Committee that listed "Gary Marx, Executive Director of the Judicial Confirmation Network, Former Executive Director of the [[Virginia Christian Coalition]]" and "[[Wendy Long]], Chief Counsel, Judicial Confirmation Network, New York."[^5]
### The 2008 Electioneering Filing
On October 2, 2008 the Judicial Confirmation Network filed a Form 9 with the [[Federal Election Commission]], a 24-hour notice of electioneering communications, from P.O. Box 3141, Manassas. It reported disbursements on September 29, 2008 to the [[Pittsburgh]] firm [[BrabenderCox]] for television and cable placement, a marketing fee and production of an advertisement titled "Chose" that named [[Barack Obama]], with a total on the form of 548,063 dollars. Neil Corkery was the custodian of records, listed as self-employed and a consultant. The persons "sharing or exercising control" were Corkery, Gary Marx, whose employer was [[Century Strategies]], and Dan Casey, whose employer was [[DC Strategies]]. Marx signed the form.[^6]
### Wellspring and the 2016 Donation
The [[Wellspring Committee]] was a Virginia organization formed in 2008 whose books and records were kept by Neil Corkery at 8665 Sudley Road, Suite 182, Manassas. Its returns show revenue of 13,243,310 dollars in 2010, 7,802,442 dollars in 2014, 9,350,040 dollars in 2015, 32,227,010 dollars in 2016 and 16,650,162 dollars in 2017. In 2016 its program services were 31,459,679 dollars, of which 29,124,997 dollars were grants.[^7]
[[Margaret Sessa-Hawkins]] and [[Andrew Perez]] of [[MapLight]] reported on October 24, 2017 that the Judicial Crisis Network's return for July 2015 to June 2016 showed a single anonymous contribution of 17.9 million dollars, "96.6 percent of its revenue," in an organization that "had never reported more than $6 million in revenue since its 2005 creation," and that Wellspring "reported giving JCN more than $15 million between 2012 and 2015." They described Corkery as JCN's longtime treasurer, his wife [[Ann Corkery]] as the person who ran Wellspring, and the JCN director [[Daniel L. Casey]] as the father of Wellspring's director [[Michael Casey]]. In May 2019 Perez and Anna Massoglia reported that Wellspring had given JCN "$23.5 million in 2016" and almost 15 million dollars in 2017, and that JCN's return for July 2017 to June 2018 listed "a $17 million contribution from a single anonymous donor" and "nine other anonymous contributions, none smaller than six figures."[^8][^9]
The return for June 2016, as read from the filed image, showed revenue of 18,545,000 dollars and expenses of 18,478,456 dollars. Its five highest paid contractors were [[Mentzer Media]] of [[Towson, Maryland]], 1,438,439 dollars for advertising and promotion; [[CRC Public Relations]] of 2850 Eisenhower Avenue, [[Alexandria]], 908,364 dollars; [[Sandler Innocenzi]], 821,797 dollars; and the [[Wickers Group]] of [[San Francisco]], 528,744 dollars. The return for June 2017 showed revenue of 25,614,292 dollars, expenses of 25,696,352 dollars, and contractors including Mentzer Media at 6,911,453 dollars, CRC Public Relations at 947,000 dollars and [[BH Group LLC]] of [[Arlington, Virginia]], at 687,500 dollars for consulting.[^2]
### Garland, Gorsuch and Kavanaugh
In July 2018 [[Matt Shuham]] of [[Talking Points Memo]] wrote that the network pledged "$1.4 million in television advertisements supporting Judge [[Brett Kavanaugh]]" nationally on cable news and in [[Alabama]], [[Indiana]], [[North Dakota]] and [[West Virginia]], and that it had earlier pledged "to spend up to $7 million stopping [[Merrick Garland]]" and up to 10 million dollars for [[Neil Gorsuch]]. [[Carrie Severino]], then chief counsel and policy director, said: "Judge Kavanaugh is a home run."[^10]
The return for June 2018 recorded total revenue of 22,045,341 dollars, expenses of 16,802,593 dollars and grants of 7,295,000 dollars, with contractors Mentzer Media at 3,585,940 dollars, CRC Public Relations at 3,348,638 dollars, BH Group at 241,000 dollars, [[IMGE Insights]] at 212,500 dollars and DDC at 187,500 dollars. In October 2018 the network filed electioneering reports with the Federal Election Commission for payments to Mentzer Media on October 2, 2018 of 217,130 dollars and 217,715 dollars; a report of December 2018 lists payments of the same date and total, 434,845 dollars, as one item described as "LOBBYING - BEST OF THE BEST MEDIA BUY," covering two candidates.[^11][^12]
The return for June 2019 reported revenue of 29,570,930 dollars and expenses of 33,658,619 dollars. Mentzer Media was paid 12,322,297 dollars for communication and promotion, CRC Public Relations 3,485,151 dollars, BH Group LLC 1,191,875 dollars for consulting, [[North Star Opinion Research]] 608,300 dollars for polling and the law firm [[Holtzman Vogel Josefiak Torchinsky]] 349,334 dollars. Daniel L. Casey, director and president until November 19, 2019, and Gary Marx, president, secretary, treasurer and director, were each paid 75,000 dollars.[^13]
### CRC Advisors
On January 7, 2020 [[Leonard Leo]] announced that he was leaving the day-to-day management of the [[Federalist Society]] to form [[CRC Advisors]] with [[Greg Mueller]], president of CRC Public Relations. "Leo will be chairman of CRC Advisors, while Mueller will be its CEO," and Leo remained co-chairman of the Federalist Society's board. The network's returns list CRC Public Relations at 2850 Eisenhower Avenue, Alexandria, in the returns for June 2016 through June 2019, and CRC Advisors at the same address in the returns for June 2021 through June 2025. CRC Advisors was paid 7,679,331 dollars for the year to June 2021, 3,757,454 dollars to June 2022, 6,058,832 dollars to June 2023, 4,092,349 dollars to June 2024 and 4,610,996 dollars to June 2025, a total of 26,198,962 dollars. The returns also list Mentzer Media at 6,194,131 dollars (2021), 5,719,496 dollars (2022) and 3,801,690 dollars (2023), BH Group at 500,000 dollars (2021), [[Creative Direct]] at 1,827,221 dollars (2021), Holtzman Vogel at 533,097 dollars (2024), the fundraising firm [[Invictus]] at 1,025,000 dollars (2025) and [[Gibson, Dunn & Crutcher]] at 382,673 dollars for legal services (2025).[^14][^15]
### Barrett and the Marble Freedom Trust
For the nomination of [[Amy Coney Barrett]] in the fall of 2020 the network announced a phase of "a $2.2 million-dollar ad blitz" and a second of "an initial $3 million-dollar ad buy," and stated that it "expects to spend at least $10 million," in [[Colorado]], [[Iowa]], [[Maine]], [[North Carolina]], [[Utah]] and [[Washington, D.C.]] Carrie Severino, "Judicial Crisis Network President," said that "President [[Donald Trump|Trump]] promised to appoint justices in the mold of Scalia and Thomas."[^16] Its return for June 2021 reported revenue of 48,134,887 dollars and listed Severino as president at 139,667 dollars, Ann Corkery as counsel at 256,063 dollars and [[Frank J. Scaturro]] as counsel at 242,500 dollars.[^3]
The [[Marble Freedom Trust]], a Utah trust led by Leo as trustee and chairman, reported total revenue of 1,642,871,821 dollars for the year ended April 30, 2021, against none in the year before. The trust was created in April 2020, and [[Barre Seid]] transferred to it 100 percent of the electronics maker [[Tripp Lite]], which [[Eaton]] bought for 1.65 billion dollars in March 2021; [[ProPublica]] and [[The Lever]] reported that Seid thereby avoided up to 400 million dollars in income tax. In a February 2021 [[Illinois]] corporate filing of Tripp Lite, "Added as an officer, written in by hand, was Leonard Leo."[^17] Marble's Schedule I lists grants to The Concord Fund of 16.5 million dollars for the year ended April 30, 2021, 28.9 million dollars for 2022, 55.5 million dollars for 2023, 60.45 million dollars for 2024 and 33.45 million dollars for 2025, a total of 194.8 million dollars. For the year to April 2021 it also listed 153 million dollars to the [[Rule of Law Trust]] and 41.1 million dollars to [[DonorsTrust]]; in later years it listed [[Schwab Charitable Fund]] grants of 153.8, 153.75, 122 and 157.65 million dollars.[^18]
The network's contributions were 29,351,842 dollars for the year to June 2022, 52,773,080 dollars to June 2023, 65,100,191 dollars to June 2024 and 26,475,000 dollars to June 2025. Marble's gifts to it in the fiscal years ended April 2023 and 2024 were 55.5 million and 60.45 million dollars.[^3][^18]
### Grants to Political Committees
The network's Schedule I for the year to June 2022 lists grants to [[One Nation]] (3 million dollars), [[Catholic Vote Civic Action]] (1.7 million), [[Americans for Limited Government]] (1.685 million), [[Independent Women's Voice]] (1.5 million), the [[Republican State Leadership Committee]] and the [[Republican Attorneys General Association]] (1 million each), [[Heritage Action for America]] (1 million) and the [[Foundation for Fair Courts]] (1 million). For June 2023 it lists the [[Susan B. Anthony List]] (8.8 million), the [[Republican Governors Association]] (6 million), the Republican Attorneys General Association (4 million) and [[Bluegrass Freedom Action]] (3 million). For June 2024 it lists [[Protect Women Ohio Action]] (17.26 million), [[Right Vote]] (8.05 million) and [[Club for Growth Action Missouri]] (3 million), and for June 2025 [[Defend Missouri]] (2.5 million), [[Truth and Courage PAC]] (2.5 million), the [[Republican Party of Florida]] (2 million), the Republican State Leadership Committee (2 million), [[Turning Point Action]] (500,000) and the [[Lexington Fund]] (200,000).[^19]
### Officers and Pay in the Last Returns
The return for June 2025, filed on May 12, 2026, reported one voting member of the governing body. Gary Marx was president, secretary, treasurer and director, unpaid; Ann Corkery was paid 395,655 dollars as counsel, Frank Scaturro 291,805 dollars and Carrie Severino 238,034 dollars. Revenue was 26,475,000 dollars, expenses 27,593,274 dollars and total assets 42,274 dollars.[^20]
### Termination and the Lexington Fund
[[Taylor Giorno]] of [[The Washington Sun]] reported on April 13, 2026 that the Concord Fund "quietly filed articles of termination on Jan. 6 of this year, according to previously unreported Virginia business records," and that in December 2025 the Lexington Fund "registered several alternative names including Judicial Crisis Network and Honest Election Project Action, according to [[Texas]] business records." The Lexington Fund's director was [[Oramel Skinner]]; its 2024 year-end report showed "just $305,000 in grants and contributions." The Concord Fund had given it 105,000 dollars between July 2023 and June 2024. The Marble Freedom Trust's return for the year ended April 30, 2025 lists a grant to the Lexington Fund of 14.75 million dollars, alongside 33.45 million dollars to The Concord Fund.[^4][^18]
### Footnotes
[^1]: Judicial Confirmation Network, Form 990 for 2005 (EIN 20-2303252), Parts I, III and V and attachments, as filed; ProPublica Nonprofit Explorer. https://projects.propublica.org/nonprofits/organizations/202303252
[^2]: Judicial Crisis Network, Forms 990 for the years ended June 30, 2016 (return for 2015) and June 30, 2017 (return for 2016), Parts I, VII and VIII; ProPublica Nonprofit Explorer, https://projects.propublica.org/nonprofits/organizations/202303252 . Figures read from the scanned images.
[^3]: The Concord Fund, Forms 990 for the years ended June 30, 2021 to 2025, Part I and Part VII; ProPublica Nonprofit Explorer extracted financial data and full-text filings, https://projects.propublica.org/nonprofits/organizations/202303252/202211369349314701/full (2021), .../202331359349303658/full (2022), .../202411359349301886/full (2023), .../202541359349307549/full (2024), .../202641359349305274/full (2025).
[^4]: Taylor Giorno, "'Dark Money' Kingpin Leonard Leo Revamps Operation Ahead of Midterms," *The Washington Sun,* April 13, 2026. https://washingtonsun.com/money/leonard-leo-concord-fund-dark-money-elections
[^5]: "Governor Mitt Romney Announces the National Faith and Values Steering Committee," Romney campaign press release, June 13, 2007, The American Presidency Project. https://www.presidency.ucsb.edu/documents/romney-campaign-press-release-governor-mitt-romney-announces-the-national-faith-and-values
[^6]: Federal Election Commission, FEC Form 9, 24 Hour Notice of Disbursements/Obligations for Electioneering Communications, Judicial Confirmation Network, received October 2, 2008 (committee C30001242), Schedule 9-B, pages 2 to 4. https://docquery.fec.gov/pdf/424/28039843424/28039843424.pdf
[^7]: Wellspring Committee Inc. (EIN 26-2046485), Form 990 for 2016, Parts I, III, VII and VIII as filed (books and records, "Neil Corkery, 8665 Sudley Rd. Ste 182, Manassas, VA 20110"; year of formation 2008), and ProPublica extracted revenue for 2010 to 2017. https://projects.propublica.org/nonprofits/organizations/262046485
[^8]: Margaret Sessa-Hawkins and Andrew Perez, "Dark Money Group Received Massive Donation In Fight Against Obama's Supreme Court Nominee," *MapLight,* October 24, 2017. https://maplightarchive.org/story/dark-money-group-received-massive-donation-in-fight-against-obamas-supreme-court-nominee/
[^9]: Andrew Perez and Anna Massoglia, "Secretive Conservative Legal Group Funded By $17 Million Mystery Donor Before Kavanaugh Fight," *MapLight* and the Center for Responsive Politics, May 17, 2019. https://maplightarchive.org/story/secretive-conservative-legal-group-funded-by-17-million-mystery-donor-before-kavanaugh-fight/
[^10]: Matt Shuham, "Judicial Crisis Network Announces $1.4 Million Ad Buy For Kavanaugh," *Talking Points Memo,* July 9, 2018. https://talkingpointsmemo.com/dc/judicial-crisis-network-kavanaugh-ad-buy
[^11]: Judicial Crisis Network, Form 990 for the year ended June 30, 2018 (return for 2017), Parts I, VII and VIII; ProPublica Nonprofit Explorer. Figures read from the scanned image.
[^12]: Federal Election Commission, committee C30001689 (Judicial Crisis Network), electioneering communications, file numbers 1265386 and 1301569, disbursement date October 2, 2018; OpenFEC API. https://api.open.fec.gov/v1/electioneering/?committee_id=C30001689
[^13]: The Concord Fund, Form 990 for the year ended June 30, 2019, Parts I, VII and VIII; ProPublica Nonprofit Explorer full-text filing 202021979349304367. https://projects.propublica.org/nonprofits/organizations/202303252
[^14]: Fred Lucas, "Trump Judicial Adviser Teams Up With Conservative PR Executive in New Initiative," *The Daily Signal,* January 7, 2020. https://web.archive.org/web/2id_/https://www.dailysignal.com/2020/01/07/trump-judicial-adviser-teams-up-with-conservative-pr-executive-in-new-initiative/
[^15]: The Concord Fund, Forms 990 for the years ended June 30, 2016 to 2025, Part VII, Section B (independent contractors); ProPublica Nonprofit Explorer.
[^16]: Judicial Crisis Network, press release, "Judicial Crisis Network (JCN) Launches New Seven-Figure Ad Buy to Confirm Judge Amy Coney Barrett," 2020. https://judicialnetwork.com/in-the-news/confirm-amy/
[^17]: "How a Secretive Billionaire Handed His Fortune to the Architect of the Right-Wing Takeover of the Courts," *ProPublica* and *The Lever,* August 22, 2022. https://www.propublica.org/article/dark-money-leonard-leo-barre-seid
[^18]: Marble Freedom Trust (EIN 85-0784793), Forms 990 for the years ended April 30, 2021 to 2025, Part I and Schedule I, Part II, Part VII; ProPublica Nonprofit Explorer. https://projects.propublica.org/nonprofits/organizations/850784793
[^19]: The Concord Fund, Forms 990 for the years ended June 30, 2022 to 2025, Schedule I, Part II; ProPublica Nonprofit Explorer full-text filings (object numbers as above).
[^20]: The Concord Fund, Form 990 for the year ended June 30, 2025 (filed May 12, 2026), Parts I, VI and VII; ProPublica Nonprofit Explorer. https://projects.propublica.org/nonprofits/organizations/202303252/202641359349305274/full

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---
category: "Private Organization"
tags:
- Organization
- Banking
- MorganGuaranty
- GuarantyTrust
- JPMorgan
- WickliffeDraper
- PioneerFund
- InterlockingDirectorates
- TrustBanking
alias:
- Morgan Guaranty Trust
- Morgan Guaranty
- Morgan Guaranty Trust Co.
- Morgan Guaranty Trust Company
- Morgan Guaranty Trust Company of New York
- Guaranty Trust Company
- Guaranty Trust Company of New York
- Guaranty Trust
summary: "New York bank formed on April 24, 1959 by the merger of J.P. Morgan and Guaranty Trust, which carried Wickliffe Draper's anonymous gifts to Mississippi in 1963 and was succeeded by JPMorgan Chase Bank."
start: 1959-04-24
location: "New York, New York"
relations:
- type: owned
with: "[[J.P. Morgan & Co.]]"
reverse: true
role: "parent holding company, 100 percent of the bank"
fn: 2
- type: represented
with: "[[Wickliffe Draper]]"
role: "private banker; executor of his estate after 1972"
fn: 8
- type: represented
with: "[[Pioneer Fund]]"
role: "asset manager under the terms of Draper's will for about two decades; account closed after The Bell Curve"
fn: 8
- type: employed_by
with: "[[Thomas S. Gates Jr.]]"
reverse: true
role: "worked for the bank after leaving the Department of Defense in January 1961"
fn: 7
- type: director_of
with: "[[Douglas A. Warner III]]"
reverse: true
start: 1990
role: "chairman of the boards of Morgan and the bank from January 1995"
fn: 11
- type: director_of
with: "[[Hanna H. Gray]]"
reverse: true
start: 1976
role: "director of Morgan; President of the University of Chicago 1978 to 1993"
fn: 11
- type: director_of
with: "[[Lee R. Raymond]]"
reverse: true
start: 1987
role: "chairman and chief executive of Exxon Mobil Corporation"
fn: 11
- type: director_of
with: "[[Riley P. Bechtel]]"
reverse: true
start: 1995
role: "chairman and chief executive of Bechtel Group"
fn: 11
- type: director_of
with: "[[Martin Feldstein]]"
reverse: true
start: 1993
role: "president of the National Bureau of Economic Research; director of American International Group"
fn: 11
- type: subject_of
with: "[[Sumitomo Corporation v. J.P. Morgan & Co.]]"
start: 1999-08
role: "defendant with J.P. Morgan & Co. Incorporated and a former employee in a copper trading suit in the Southern District of New York"
fn: 12
created: 2026-10-01
updated: 2026-10-01
---
Morgan Guaranty Trust Company of New York was formed on April 24, 1959 by the merger of [[J.P. Morgan & Co.]] Incorporated and the Guaranty Trust Company of New York. A Senate staff study of January 1978 recorded that J.P. Morgan held all of its stock and that in 1976 it was "among the top 5 stockvoters in almost one-half of the 130 companies in the study." After J.P. Morgan merged into [[Chase Manhattan Corporation]] on December 31, 2000, the bank was "succeeded through merger by [[JPMorgan Chase]] Bank."[^1][^2][^3]
### Guaranty Trust and the Russian Account
On July 15, 1916 the Imperial Russian Government opened an account at the Guaranty Trust Company; on July 12, 1917 the financial attache of the Russian Embassy deposited 5,000,000 dollars in it. When the [[Soviet Union|Soviet government]] succeeded the Provisional Government in November 1917, about 5,000,000 dollars remained on deposit. On February 25, 1918 the bank applied the balance "as a credit against indebtedness alleged to be due to it by the Russian Government by reason of the latter's seizure of certain ruble deposit accounts of petitioner in Russian private banks." After the [[United States]] recognized the Soviet government on November 16, 1933 it took an assignment of such claims and sued the bank on September 21, 1934. In *Guaranty Trust Co. of New York v. United States*, 304 U.S. 126, decided on April 25, 1938 with [[John W. Davis]] arguing for the bank, the [[Supreme Court of the United States]] held that the New York six-year statute of limitations applied and reversed the [[United States Court of Appeals for the Second Circuit|Second Circuit]].[^4]
### The Business Plot Hearings
In November 1934 the [[McCormack-Dickstein Committee|House Special Committee on Un-American Activities]] heard Major General [[Smedley Butler]], who testified that [[Gerald P. MacGuire|Gerald MacGuire]], a bond salesman at [[Grayson M.-P. Murphy & Co.]], 52 Broadway, had proposed that he lead a veterans' organization. Butler said MacGuire gave him two names as the source of the money: "Colonel Murphy, Grayson M.-P. Murphy, for whom he worked, was one." MacGuire told the committee that Murphy was "my boss." Murphy had been senior vice president of Guaranty Trust from 1915 to 1917 and again from 1919 to 1920, and in 1936 was treasurer of the [[American Liberty League]], according to *Who's Who in Commerce and Industry.* The writer [[Antony C. Sutton]] described him as a director of the Guaranty Trust Company at the time of the hearings.[^5][^6]
On November 24, 1934 the committee's statement said that it had "no evidence before it that would in the slightest degree warrant calling before it such men as John W. Davis, [[Hugh S. Johnson|Gen. Hugh Johnson]], [[General Harbord]], [[Thomas W. Lamont]], [[Admiral Sims]], or [[Hanford MacNider]]."[^5] The reproduced release and testimony of the [[Business Plot]] hearings name Murphy as MacGuire's employer and as one of two sources of the money and do not mention the Guaranty Trust Company.[^5]
### The 1959 Merger
According to the international year books, the bank resulted "through the merger of J. P. Morgan & Co. Incorporated and Guaranty Trust Company of New York on 24 April 1959," with [[Henry C. Alexander]] as chairman in the early 1960s. [[Thomas S. Gates Jr.]], [[United States Secretary of the Navy|Secretary of the Navy]] from 1957 and Deputy Secretary and then Secretary of Defense under [[Dwight D. Eisenhower]] until January 1961, "returned to investment banking, working for the Morgan Guaranty Trust Company," before President [[Gerald Ford]] named him in 1976 Chief of the United States Liaison Office in [[Beijing]].[^1][^7]
### Draper's Accounts
[[Wickliffe Draper]] had been a client of Guaranty Trust since the 1930s. In 1940 the [[Pioneer Fund]] offered to establish annuities for the education of any child born that year to an officer of the [[United States Army Air Corps]] who had already fathered at least three children; according to the records of the fund's director [[John Marshall Harlan II]], Draper arranged for an annuity to be established for each of the twelve children at Guaranty Trust.[^8]
### Mississippi, 1963 and 1964
After President [[John F. Kennedy]]'s civil rights address of June 1963 the lawyer [[John C. Satterfield]] of [[Yazoo City]], a past president of the [[American Bar Association]], organized the [[Coordinating Committee for Fundamental American Freedoms]] in [[Washington, D.C.]]; the [[Mississippi]] State [[Mississippi State Sovereignty Commission|Sovereignty Commission]], according to the state archives, "participated in the national campaign to prevent the passage of the 1964 Civil Rights Act, establishing and providing funds for" it.[^9] On July 22, 1963 Satterfield received the first private contribution, a 10,000 dollar Morgan Guaranty cashier's check drawn on Draper's accounts, which was deposited in a special account in the state treasury and logged in the commission's records as "Morgan Guaranty Trust Co." Contributions from Mississippi residents never exceeded 30,000 dollars. A surviving partner of Satterfield's firm said Satterfield referred obliquely to the source of the large money as "the Wall Street gang."[^8]
On September 12, 1963 the bank's vice president [[Arthur W. Rossiter Jr.]] telegraphed Governor [[Ross Barnett]] that a client was "setting aside as an anonymous gift" stock valued at 100,000 dollars on the condition that "the fact and amount of the gift to be kept confidential." Barnett agreed the same day. After the shares were sold the gift totaled 98,612 dollars and was entered in the commission's records as "Donation from Morgan Guaranty Trust Company." Four months later Rossiter sent a second telegram announcing an additional 105,000 dollars. The money came from Draper's shares of [[R.J. Reynolds Tobacco Company|Reynolds Tobacco]], [[General Motors]], [[Standard Oil|Standard Oil of New Jersey]] and [[Addressograph-Multigraph]]; the bank sold the stock at Draper's direction, collected commissions on the sales and held the proceeds in what it called a temporary Sovereignty Commission account at Morgan Guaranty. In one letter Rossiter wrote: "This represents an anonymous gift to your Commission and the donor has specifically requested that the fact and the amount of the gift be kept strictly confidential."[^8]
Nearly 215,000 dollars of the campaign's budget of about 300,000 dollars came through the bank. The committee bought advertisements in 500 daily and weekly newspapers and by April 1964 had distributed 1.4 million pamphlets and mailings. An internal memorandum by Satterfield said Americans had to be shown that the conditions of Black people in the United States resulted from "heredity . . . not discrimination," and named "the intelligence, criminality and immorality of the Negro."[^8] On June 2, 1964 a further 50,000 dollars from Draper arrived through the bank for a proposed permanent national organization. After the murders of [[James Chaney]], [[Andrew Goodman]] and [[Michael Schwerner]] that summer the plan was dropped and the 50,000 dollars was returned to Draper's lawyer [[Harry Weyher]], who deposited it in his firm's escrow account.[^8]
The state treasurer at the time, [[William F. Winter]], said that Wall Street firms charged higher interest rates on Mississippi bonds because of the state's reputation, and that a bond issue was canceled in 1965 for lack of bids on Wall Street.[^8]
### The Estate and the Pioneer Fund
When Draper died in 1972 the bank continued to manage his holdings while the will was sorted out, and five years later the assets were distributed: about 1 million dollars to family members, 3.3 million dollars to the Pioneer Fund and 1.7 million dollars to the [[Puritan Foundation]], which listed Satterfield's law firm as its address. In 1978 the Puritan Foundation was merged into the [[Council School Foundation]], which supported private schools for white students. In the late 1960s and 1970s Draper had sent dozens of checks to private academies opened for white families after public school integration. His will instructed the fund to use the bank for financial advice, and it did so for two decades. [[Douglas A. Blackmon]] reported in 1999, citing people familiar with the situation, that the bank closed the Pioneer Fund's asset management account after the controversy over *[[The Bell Curve]]* in 1994; the bank would not give details of why.[^8]
The bank said that "racism is deplorable," that it did not "support institutions that further racist causes," and that it had given more than 3.3 million dollars of its own money to civil rights groups since the late 1960s. Its spokesman [[Joe Evangelisti]] said: "A thousand times a day, somebody sends money to an organization that 30 years later looks really terrible. We can't tell our customers how to spend their money." The managing director [[Hildy J. Simmons]] said: "As long as the receiving party is legal, we have no discretion," and, of Draper: "You can spend your money the way you want to." The files of the commission, sealed by the 1977 abolition act, were opened by a federal court order, most of them becoming available in the state archives' search room on March 17, 1998, and the [[The Wall Street Journal|Wall Street Journal]] reported the transfers on June 11, 1999.[^8][^9]
### Holdings and Interlocks in 1978
The Senate Committee on Governmental Affairs staff study, *Interlocking Directorates Among the Major U.S. Corporations* (January 1978), recorded that "J. P. Morgan holds 100 percent control of Morgan Guaranty Trust Co. of New York, which is the Nation's largest holder of voting stock in U.S. corporations." It described J.P. Morgan as the "parent of the Nation's largest institutional investor." The study counted indirect interlocks through shared boards: Citicorp's directors met J.P. Morgan's directors 30 times on 19 other boards and those of [[Chase Manhattan Bank]] 17 times on 9 boards. J.P. Morgan was directly interlocked with General Motors three times and with [[Ford Motor Company|Ford]] once.[^2]
### J.P. Morgan in 1994
In its annual report for 1994 J.P. Morgan stated that it was "a primary dealer in government securities of the United States and all other [[Group of Seven]] industrial nations," that its sales and trading clients and counterparties included "corporations, central banks, governments and their agencies," and that the assets it managed had grown in 1994 to 150 billion dollars. Its equity portfolio "exceeds $1 billion in value and includes securities of 90 companies"; the largest gain came from [[Columbia/HCA]] stock acquired in 1989 "in connection with our role in the leveraged acquisition of [[Hospital Corporation of America]] by its management."[^10]
### The Board in 2000
The proxy statement for the annual meeting of April 12, 2000 nominated 15 directors of J.P. Morgan & Co., each "also a director of Morgan Guaranty Trust Company of New York." They included the chairman [[Douglas A. Warner III]], a director of [[General Electric]] and [[Anheuser-Busch]] and a member of the Board of Counselors of [[Bechtel Group]]; [[Riley P. Bechtel]], chairman and chief executive of Bechtel Group and a member of the [[Trilateral Commission]]; [[John A. Krol]], retired chairman of [[E.I. du Pont de Nemours and Company]] and a member of the advisory board of [[Bechtel Corporation]]; [[Lee R. Raymond]], chairman of [[Exxon Mobil Corporation]], a member of the [[Council on Foreign Relations]] and the Trilateral Commission, director since 1987; [[James R. Houghton]] of [[Corning Incorporated|Corning]] and a director of Exxon Mobil and [[Metropolitan Life Insurance Company]]; [[Martin Feldstein]], also a director of Columbia/HCA, and [[Ellen V. Futter]], who with Feldstein sat on the board of [[American International Group]] and was a member of the Council on Foreign Relations; [[Hanna H. Gray]], a director since 1976; and [[Paul A. Allaire]] of [[Xerox]], also a member of the Council on Foreign Relations. The proxy listed Corning, DuPont, Exxon Mobil, [[Honeywell]], [[Maytag]], [[Phelps Dodge]] and Xerox as organizations whose officers sat on the board and with which J.P. Morgan had transactions in the ordinary course.[^11]
### Sumitomo Copper Litigation
In August 1999 [[Sumitomo Corporation]] sued J.P. Morgan & Co. Incorporated, Morgan Guaranty Trust Company of New York "and a former J.P. Morgan employee" in the [[Southern District of New York]], alleging that from 1993 to 1996 Morgan had assisted a Sumitomo employee in copper trading.[^12]
### The Chase Merger
On December 31, 2000 J.P. Morgan & Co. Incorporated "merged with and into The Chase Manhattan Corporation," which was renamed J.P. Morgan Chase & Co.; a merger charge of 1.25 billion dollars was recorded that day. The bank itself was succeeded by JPMorgan Chase Bank.[^3]
### Footnotes
[^1]: *The International Year Book and Statesmen's Who's Who* (1974, 1975 and 1983 editions), entry for the bank ("through the merger of J. P. Morgan & Co. Incorporated and Guaranty Trust Company of New York on 24 April 1959"); 1963 edition ("Chairman, Henry C. Alexander"). https://archive.org/details/internationalyea0000john
[^2]: U.S. Senate, Committee on Governmental Affairs, Subcommittee on Reports, Accounting and Management, *Interlocking Directorates Among the Major U.S. Corporations: A Staff Study,* Committee Print, 95th Cong., 2d sess. (January 1978), summary of findings. https://archive.org/details/interlockingdire00unit
[^3]: J.P. Morgan Chase & Co., Form 10-K405 for 2001 (filed March 22, 2002), Item 1, Item 14 Exhibit 4.1, and Management's Discussion. https://www.sec.gov/Archives/edgar/data/19617/000095012302002823/y57010e10-k405.htm
[^4]: *Guaranty Trust Co. of New York v. United States,* 304 U.S. 126 (1938) (No. 566, argued March 28 and 29, decided April 25, 1938; opinion of Stone, J.). https://www.law.cornell.edu/supremecourt/text/304/126
[^5]: House Special Committee on Un-American Activities (McCormack-Dickstein Committee), *Investigation of Un-American Activities,* statement of November 24, 1934 and testimony of Smedley D. Butler, Paul Comly French and Gerald P. MacGuire, November 20 to 22, 1934, as reproduced in "The Plot to Overthrow FDR." https://archive.org/details/McCormackDicksteinCommittee ; Antony C. Sutton, *Wall Street and FDR* (Arlington House, 1975), ch. 10. https://archive.org/details/wall-street-and-fdr-1975
[^6]: *Who's Who in Commerce and Industry* (1936), entry "Murphy, Grayson Mallet-Prevost" ("Senior Vice-Pres., Guaranty Trust Co., 1915-17"; "Resumed position with Guaranty Trust Co., 1919-20"; "Treas., American Liberty League"). https://archive.org/details/whoswhoincommerc00unse_0
[^7]: University of Pennsylvania, Kislak Center, finding aid for the Thomas Sovereign Gates, Jr. papers, biographical note; Gerald R. Ford Library, nomination of Thomas S. Gates as Chief of the U.S. Liaison Office, Beijing, 1976. https://findingaids.library.upenn.edu/records/legacy/upenn_rbml_PUSpMsColl1135
[^8]: Douglas A. Blackmon, "Silent Partner: How the South's Fight To Uphold Segregation Was Funded Up North," *The Wall Street Journal,* June 11, 1999, p. A1, reproduced at https://slaverybyanothername.com/other-writings/silent-partner-how-the-souths-fight-to-uphold-segregation-was-funded-up-north/
[^9]: Mississippi Department of Archives and History, Sovereignty Commission Online, "Agency History." https://da.mdah.ms.gov/sovcom/scagencycasehistory
[^10]: J.P. Morgan & Co. Incorporated, Form 10-K405 for 1994 (filed March 22, 1995), letter to stockholders and "Description of business." https://www.sec.gov/Archives/edgar/data/68100/0000068100-95-000274.txt
[^11]: J.P. Morgan & Co. Incorporated, definitive proxy statement (Schedule 14A) for the annual meeting of April 12, 2000, filed March 8, 2000, "Item 1: Election of directors," "Transactions with directors and officers." https://www.sec.gov/Archives/edgar/data/68100/0000891092-00-000171.txt
[^12]: J.P. Morgan Chase & Co., Form 10-K405 for 2001, Item 3, "Legal proceedings" (Sumitomo Corporation v. J.P. Morgan & Co. Incorporated, Morgan Guaranty Trust Company of New York, S.D.N.Y., filed August 1999). https://www.sec.gov/Archives/edgar/data/19617/000095012302002823/y57010e10-k405.htm

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---
category: "Private Organization"
tags:
- Organization
- LawFirm
- SullivanAndCromwell
- JohnFosterDulles
- AllenDulles
- IGFarben
- UnitedFruit
- FTX
- RevolvingDoor
- WallStreet
alias:
- Sullivan & Cromwell
- Sullivan and Cromwell
- Sullivan & Cromwell LLP
- Sullivan and Cromwell LLP
- S&C
summary: "New York law firm founded in 1879 whose partners included John Foster Dulles and Allen Dulles, and whose clients ranged from the Schroder bank to the FTX group and Samuel Bankman-Fried."
start: 1879-04-02
location: "New York, New York"
relations:
- type: founded
with: "[[William Nelson Cromwell]]"
reverse: true
start: 1879-04-02
role: "co-founder"
fn: 1
- type: founded
with: "[[Algernon Sydney Sullivan]]"
reverse: true
start: 1879-04-02
role: "co-founder"
fn: 1
- type: employed_by
with: "[[John Foster Dulles]]"
reverse: true
start: 1927
role: "sole managing partner from 1927"
fn: 2
- type: employed_by
with: "[[Allen Dulles]]"
reverse: true
start: 1926-10
role: "lawyer; leave for the Office of the Coordinator of Information and the Office of Strategic Services; of counsel from 1961"
fn: 2
- type: employed_by
with: "[[Arthur H. Dean]]"
reverse: true
role: "partner; counsel to Standard Oil Company (New Jersey) in the oil cartel case"
fn: 18
- type: employed_by
with: "[[Peter Thiel]]"
reverse: true
role: "securities lawyer before 1996"
fn: 28
- type: employed_by
with: "[[William Bradford Reynolds]]"
reverse: true
start: 1967
role: "associate"
fn: 29
- type: employed_by
with: "[[Keith Rabois]]"
reverse: true
role: "attorney before joining PayPal"
fn: 31
- type: employed_by
with: "[[Jamie McDonald]]"
reverse: true
role: "partner and co-head of the securities and commodities investigations practice after 2020"
fn: 35
- type: employed_by
with: "[[Jay Clayton]]"
reverse: true
start: 2001
end: 2017
role: "partner"
fn: 32
- type: represented
with: "[[New Panama Canal Company]]"
role: "counsel to the French canal company; Cromwell later general counsel and fiscal agent of Panama"
fn: 5
- type: represented
with: "[[J. Henry Schroder Banking Corporation]]"
role: "longtime client, financial agent for United Fruit, American and Foreign Power and International Railways of Central America"
fn: 3
- type: represented
with: "[[United Fruit Company]]"
role: "client for most of the company's existence, per Stephen Kinzer"
fn: 3
- type: represented
with: "[[Standard Oil]]"
role: "Standard Oil Company (New Jersey), defense of the international oil cartel case through Arthur H. Dean"
fn: 18
- type: represented
with: "[[Anglo-Iranian Oil Company]]"
role: "client through Allen Dulles"
fn: 25
- type: represented
with: "[[Ernest K. Halbach]]"
end: 1945-01-27
role: "counsel (Stoddard M. Stevens Jr.) in the General Dyestuff Corporation stock case against the Alien Property Custodian"
fn: 21
- type: represented
with: "[[FTX]]"
start: 2021-07
role: "acquisition and regulatory counsel before the petition; debtors' counsel from 2022-11-11"
fn: 38
- type: represented
with: "[[Sam Bankman-Fried]]"
start: 2022-04-14
end: 2022-08-05
role: "regulatory advice on his purchase of Robinhood shares; about $195,000 in fees paid through Alameda Research"
fn: 41
- type: represented
with: "[[Leon Black]]"
role: "estate planning memorandum of July 12, 2017 forwarded to Jeffrey Epstein"
fn: 37
- type: subject_of
with: "[[Garrison v. Sullivan & Cromwell]]"
start: 2024-02-16
role: "putative class action by FTX investors in the Southern District of Florida, voluntarily dismissed in October 2024"
fn: 43
created: 2026-10-01
updated: 2026-10-01
---
Sullivan & Cromwell is a [[New York City]] law firm formed on April 2, 1879 by [[Algernon Sydney Sullivan]] and [[William Nelson Cromwell]]. [[John Foster Dulles]] became its sole managing partner in 1927 and his brother [[Allen Dulles]] joined in October 1926; in 1953 John Foster Dulles became [[United States Secretary of State|Secretary of State]] and Allen Dulles [[Director of Central Intelligence]]. In the 1930s the firm's clients included [[International Nickel Company|International Nickel]], the [[J. Henry Schroder Banking Corporation]] and the companies of the [[United Fruit Company]] group. In 2022 its sworn disclosures in the [[FTX]] bankruptcy listed [[Sam Bankman-Fried]] as a former client and named competitors, counterparties and banks of the FTX group among its current ones.[^1][^2][^3][^4]
### Panama
The firm's first international matter of size was the sale of the assets of the French Panama canal enterprise. Cromwell was hired by the Paris-based New [[Panama Canal]] Company, and after the [[Isthmian Canal Commission]] fixed a price of 40 million dollars he submitted to his client a bill for 800,000 dollars, "amounting to 2 percent of a tough transaction." The company rejected it and took the fee to a French arbitrator; the firm retained the French senator and lawyer [[Raymond Poincare]], who obtained no more than 200,000 dollars for eight years of work. Cromwell was appointed general counsel and fiscal agent of the new Republic of [[Panama]].[^5]
The firm's own account of the canal work survives in the brief it filed with the French arbitrators to justify the fee, which the [[House Committee on Foreign Affairs]] printed in full in 1913 during hearings on a resolution of Representative [[Henry T. Rainey]]. The brief recorded a letter of February 21, 1897 in which Cromwell proposed to the company a plan of action "different, open, audacious, aggressive," and a letter from the firm to President [[William McKinley]] of April 30, 1900. It also described how, in the presidential year 1900, "Mr. Cromwell saw Senator [[Mark Hanna|Hanna]] and other Republican leaders and urged that the Republican Party should not again pledge itself to the cause of Nicaragua," and how the words "an isthmian canal" replaced "the Nicaragua Canal" in the [[Republican Party]] platform.[^6]
Rainey told the committee that Cromwell had given 60,000 dollars to the Republican campaign in 1900, that the money "came directly from the Panama Canal company in Paris," and that "Mr. Cromwell charged it up there as a part of his necessary expenses." He said the evidence had been placed before him by the [[New York World]], which had collected it to defend the criminal libel suit the government of the [[United States]] brought against the paper. The World's reporter [[Henry N. Hall]] testified that the 60,000 dollars went to the [[Republican National Committee]], "of which Senator Hanna was chairman," and, asked for his authority, named a statement by [[Philippe Bunau-Varilla]] to [[Don C. Seitz]] of the World. Bunau-Varilla, in a statement printed with the hearings, called the attribution "a pure fiction" and said that when Cromwell sought reinstatement as the company's counsel in 1902 he described the account outstanding as "only a trifling matter of one or two thousand dollars." Hall told the committee that the brief showed how Cromwell "planned a revolution when he saw that the treaty never would be accepted by [[Colombia]]."[^6]
In an episode the firm's 1988 historians placed in John Foster Dulles's years as an associate, the United Fruit Company and a New York banker tried to have Panama remove Cromwell as fiscal agent. The [[State Department]]'s solicitor, [[Robert Lansing]], who was Dulles's uncle, lobbied for Cromwell and wrote that "the Fruit Company [is trying] to extend its dominion into Panama." The authors stated that Dulles "put even Cromwell in his debt."[^7]
### The Dulles Brothers' Arrival
[[Royall Victor]], the managing partner, died in May 1926 after collapsing on his yacht at Oyster Bay. Cromwell appointed a four-man directorate of John Foster Dulles, [[Wilbur L. Cummings]], [[Edward Green]] and [[Eustace Seligman]]; Dulles took over from Cromwell the accounts of International Nickel, [[American Bank Note]], [[Cuban Cane Sugar]] and the [[Gold Dust Corporation]], and handled European work through [[Arthur H. Dean]], [[Norris Darrell]] and [[George Sharp]]. Allen Dulles started at the firm in October 1926, and in 1927 John Foster Dulles became sole managing partner.[^2]
[[Stephen Kinzer]] wrote that Allen Dulles helped the Schroder bank "expand from Germany to become a global financial power" and that he did well "with timely investments in several companies his firm represented, among them International Nickel, [[Babcock & Wilcox]], and United Fruit."[^8]
### Loans to Germany and the Berlin Office
From 1924 to 1931 the firm handled 1.15 billion dollars in loans to Germany and the rest of Europe, 250 million dollars to [[Latin America]] and 139 million dollars to [[Japan]]. To manage the volume it started a Berlin firm, [[Albert & Westrick]], led by [[Heinrich Albert]], a German agent in the United States before American entry into the First World War who was deported, and his associate [[Gerhard Westrick]].[^9]
After the [[Nazi Party]] took power in 1933, cables from the firm's Berlin office carried the salutation "Heil Hitler," which [[Lauson Stone]], a lawyer who received the correspondence in New York, found shocking. Dulles had frequent appointments with representatives of [[I.G. Farben]] and [[Solvay]]. In June 1935 Allen Dulles visited Berlin, was met at the airport by the firm's [[Joseph Grazier]], spent a day seeing "our lawyer friends Albert, Westrick, etc.," and on returning told his brother to close the office. At a partners' meeting Allen Dulles said the firm "would suffer more if they didn't abandon" it, and Arthur Dean said: "In view of the fact that Edward Green, Eustace Seligman and Art Jaretzki, Jr., were Jews, it would seem better to me if we didn't represent in any way any German clients." One version recorded that John Foster Dulles "capitulated, 'in tears.'" Dean later said: "There was no argument, no confrontation, no threat to take action if Foster didn't agree."[^10]
A 1957 authorized biography by [[John Robinson Beal]] stated that "the Berlin office was closed in 1934 and German firms were notified that Sullivan & Cromwell wished to sever further connections," and [[I.F. Stone]] quoted that passage in April 1957. The authors of the 1988 history of the firm, [[Nancy Lisagor]] and [[Frank Lipsius]], placed the partners' meeting after Allen Dulles's June 1935 trip and wrote that Dulles "soon obfuscated the date of the office's actual closing, conveniently moving it back to 1934."[^10][^11] Albert & Westrick was disbanded with the loss of the firm's business, and in 1936 the German government chose Albert to head the [[Ford Motor Company]] in Germany.[^12]
### Allied Chemical, Schroder and Axis Contacts
In the early 1930s the firm represented Solvay, the Belgian owner of 20 percent of the [[Allied Chemical and Dye Corporation]] and a partner of I.G. Farben in the chemical cartel, in a proxy fight against Allied's management. [[Rogers Lamont]], an associate who had worked in the Berlin office, acted as secretary of the stockholders' committee; Allied's president, [[Orlando F. Weber]], had referred to "foreign-subsidized cartels." Lamont left the firm for the British army and was killed on May 27, 1940; Albert had written to Dulles in December 1939, "Is it true that Lamont has gone as volonteer to England in order to fight us?"[^12][^13]
In 1937 Allen Dulles joined the board of the J. Henry Schroder Bank, the American subsidiary of the London bank that [[Time]] magazine called in 1939 "an economic booster of the Rome-Berlin Axis." In 1938 and 1939 he tried to help German buyers acquire the American Potash and Chemical Corporation, and in the summer of 1938 John Foster Dulles represented the Bank of Spain in an effort to collect 15 million dollars.[^14] Kinzer wrote that the Schroder Banking Corporation, "another longtime Sullivan & Cromwell client, served as financial agent for" United Fruit, [[American and Foreign Power Company|American and Foreign Power]] and [[International Railways of Central America]]. In the 1949 special election for the [[United States Senate]] in New York, Dulles's Democratic opponents charged that his work for the Schroder bank and other German firms made him "a lawyer for those who built up the Nazi Party."[^3][^15]
In 1940 Westrick, by then Hitler's representative in the United States, called on Dulles in New York; Dulles "met willingly with Westrick, as did Dulles's son [[Avery Dulles|Avery]]." A lawyer named [[Thomas Childs]], who had wanted the firm to represent the British government, said that the British "recalled the Westrick ploy then, and thought it serious enough to turn away from Sullivan & Cromwell."[^16]
### Wartime Intelligence
Allen Dulles headed the Office of the Coordinator of Information, then went to [[Bern]] for the [[Office of Strategic Services]]. In 1945 he took a leave of absence from the firm to recruit former German intelligence officers for the unit that became the [[Central Intelligence Agency]], and he returned to Sullivan & Cromwell in New York in 1946.[^17]
### The Oil Cartel Case
On January 11, 1953, the week of John Foster Dulles's confirmation hearing, the [[Department of Justice]] offered to drop criminal charges and bring only a civil suit against the oil-cartel defendants if they produced the documents requested in the criminal case. Arthur Dean, speaking for the thirty-five lawyers for the companies and for [[Standard Oil|Standard Oil Company (New Jersey)]], called the offer "outrageous blackmail" and said: "If it were not for the question of national security, we would be perfectly willing to face either a criminal or a civil suit." Two months later the new administration abandoned the criminal investigation without asking concessions. Dulles had the [[National Security Council]] set up a special committee to "screen evidence and segregate from public disclosure evidence with national security implications"; the Justice Department catalogued his actions, and Lisagor and Lipsius called the result "a clear conflict of interest, considering his close ties to the defendants' counsel."[^18]
Dulles asked Dean to negotiate the [[Korean War]] prisoner exchange, telling the Republican National Committee chairman [[Leonard Hall]] that "there might be criticism about his taking someone from his old firm." Dean told Dulles he would not let the assignment interfere with the oil litigation because "no one else is prepared"; a week later the judge who was to hear the argument withdrew for health reasons and the proceedings were postponed indefinitely. Dulles also wrote to Hall that with himself as Secretary of State, Allen as "Deputy CIA" and Norris Darrell as Under Secretary of the Treasury, "a rather frightening picture could be drawn by unfriendly persons." Darrell stayed in New York and was used to draft the [[Internal Revenue Code of 1954]]. Handwritten notes for Dulles's January 1953 confirmation hearing referred to "[[Alger Hiss|Hiss]]," "bipartisan foreign policies," and "Cromwell estate," the last, in the authors' account, concerning aid to the Soviets.[^19]
### Vested German Property
In 1953 and 1954 a special subcommittee of the [[Senate Judiciary Committee]] chaired by Senator [[Everett Dirksen]] held hearings on amending the [[Trading with the Enemy Act]] to return property vested by the [[Alien Property Custodian]]. At the hearing of July 20 to 22, 1953, Ernest K. Halbach, president of the [[General Dyestuff Corporation]], told the senators that the Sullivan & Cromwell lawyer who represented him had repeatedly warned him that his stock option put his job at risk if he did not settle, and had told him when the case was settled: "Ernest, you are a very sensitive man and if you go on with this trial you are going to kill your wife."[^20]
The Halbach case was summarized in the record of the July 1 and 2, 1954 hearing on S. 3423. Four thousand seven hundred twenty-five shares of General Dyestuff, a sales subsidiary of [[General Aniline & Film|General Aniline and Film Corporation]], had been transferred to Halbach before the Second World War and were vested in June 1942 as the property of I.G. Farben. He was represented by [[Stoddard M. Stevens Jr.]] of Sullivan & Cromwell, and on January 27, 1945, two days before trial, the Custodian paid him 557,500 dollars (118 dollars a share). In 1951 Halbach sought to reopen the settlement on a claim of duress, and Judge McLaughlin found a "complete failure to prove duress."[^21]
On July 2, 1954, Secretary of State Dulles testified at that hearing that "there is no objection from any foreign policy viewpoint to the return, as a matter of grace, of vested German property and of Japanese property," and that "I would like to see a return to our historic position, the position of the sanctity of private property in time of war." The [[Nashville]] lawyer [[Cecil Sims]], who opposed the bill, said in his testimony that Halbach "was represented by Sullivan & Cromwell, which I consider to be the finest law firm in the United States, with one possible exception in [[Tennessee]]."[^21]
Lisagor and Lipsius wrote that Dulles "turned to Sullivan & Cromwell to carry out his support for Germany," that the Custodian's holdings were valued between 15 million and 200 million dollars "depending on the valuation of Sullivan & Cromwell client General Aniline & Film," and that Dulles tried to have the Attorney General postpone the sale of the [[Hugo Stinnes Corporation]], calling Dean to "get help in making sure Germans bought the shares." Dean spoke with [[Andre Meyer]] of [[Lazard Freres]]. The [[Deutsche Bank]] of Frankfurt was the sole bidder, and the authors wrote that Dean's role "remains submerged in classified documents," identified only as the "Stinnes matter."[^22]
### United Fruit and Guatemala
Kinzer wrote that United Fruit "was a prized Sullivan & Cromwell client" for most of its existence, that Foster and Allen Dulles both did legal work for it and "both reportedly held substantial blocks of United Fruit stock," and that the firm represented American and Foreign Power Company, owner of the electric company of [[Guatemala]], and International Railways of [[Central America]], owner of its railway network. The company's former vice president [[Thomas McCann]] wrote that its longtime general counsel [[Sam G. Baggett]] told him Dulles "was reputed to be the author of the actual concessions" negotiated for United Fruit, among them the 1936 agreement with General [[Jorge Ubico]] that gave the company 99 years' rule over tracts amounting to one-seventh of Guatemala's arable land and control of its only port.[^3]
On June 21, 1954, [[I.F. Stone's Weekly]] wrote that the law firm in which Dulles was senior partner "is counsel for International Railways, which controls the transport system of Guatemala for United Fruit, and counsel for the Schroder bank, which served German coffee interests whose plantations in Guatemala were expropriated in the last war."[^23] On June 27, 1954 the Guatemalan commanders gave President [[Jacobo Arbenz]] a "final ultimatum" and he announced on radio that he would surrender power, in the coup the Central Intelligence Agency ran as [[Operation PBSUCCESS]]. Dulles testified on vested property five days later.[^21][^24]
### Iran, Suez and Cuba
According to Lisagor and Lipsius, "Through Allen Dulles, the firm represented the Anglo-Iranian Oil Company," and after the overthrow of [[Mohammad Mossadegh]] the firm helped "smooth the way for a redivision that cut the major American oil companies in on the British concession." Kinzer wrote that the Schroder Banking Corporation, on whose board Allen Dulles sat, served as financial agent for Anglo-Iranian, and that John Foster Dulles was then seeking business in Iran for another client of the firm, the [[Chase Manhattan Bank]]. In October 1956 Dean met the Israeli ambassador [[Abba Eban]] about Egypt's closure of the [[Suez Canal]] to Israeli ships and told Dulles he would "go back and get hold of execs of Standard Oil of NJ."[^25][^26]
A Sullivan & Cromwell partner, [[Laurence A. Crosby]], resigned in 1946 to live in [[Cuba]], where he held executive positions in sugar companies and chaired the U.S. Cuban Sugar Council from 1954 to 1960; Lisagor and Lipsius wrote that the Dulles brothers "had access to information about Castro" through him.[^27]
### Washington Alumni
Allen Dulles returned to the firm after the [[Bay of Pigs invasion]] as a 50,000 dollar a year of counsel, served on the [[Warren Commission]] in 1963 and then resumed at 16,000 dollars a year. Dean negotiated the nuclear test ban treaty in 1961 and 1962 with the rank of ambassador, and, after writing to President [[Lyndon B. Johnson]] on his 1964 election and 1965 State of the Union message, proposed a Committee for an Effective and Durable Peace in Asia whose advertisement solicited funds sent to the firm at 48 Wall Street. A catalogue prepared for the 1979 centennial counted 739 lawyers who had passed through the firm, among them "a secretary of state, an attorney general, and a director of the Central Intelligence Agency."[^27][^28]
[[William Bradford Reynolds]] began his legal career at the firm in 1967 and practiced there for three years; he joined the Justice Department in 1973 as an assistant to the [[Solicitor General of the United States|Solicitor General]] and in 1981 became [[Assistant Attorney General for Civil Rights]].[^29] [[Peter Thiel]], according to [[PayPal]]'s 2001 registration statement, "practiced securities law with Sullivan & Cromwell" before trading derivatives and, from September 1996, managing Thiel Capital Management.[^30] [[Keith Rabois]], an executive of PayPal and later a director of [[Affirm]], "has also practiced as an attorney at Sullivan & Cromwell," according to Affirm's 2020 registration statement.[^31] [[Jay Clayton]], a partner from 2001 until 2017, became chairman of the [[Securities and Exchange Commission]] on May 4, 2017.[^32] As the SEC's former chairman and [[Apollo Global Management]]'s lead independent director, he was named non-executive chairman of Apollo on March 22, 2021, succeeding its founder [[Leon Black]], whose estate-planning memorandum from the firm had been forwarded to [[Jeffrey Epstein]] in 2017.[^33] The judges of the [[United States District Court for the Southern District of New York]] appointed Clayton, already serving there as interim United States Attorney by appointment of the Attorney General, United States Attorney for the district effective August 20, 2025. The Senate confirmed him as [[Director of National Intelligence]] on July 28, 2026 by 51 votes to 47.[^34] The website of the [[U.S. Attorney's Office for the Southern District of New York|United States Attorney's Office for the Southern District of New York]] states that [[Jamie McDonald]], after serving as an assistant United States Attorney until 2017 and as director of enforcement of the [[Commodity Futures Trading Commission]] from 2017 to 2020, was a partner of Sullivan & Cromwell and co-head of its securities and commodities investigations practice, and he is listed as the office's United States Attorney.[^35]
### The 2008 Financial Crisis
[[H. Rodgin Cohen]], a partner of the firm, was involved in the fall of 2008 in "the failed attempts to find a buyer for Lehman Brothers, the federal government's takeover of Fannie Mae, the government's bailout of AIG, and Wells Fargo's purchase of Wachovia," and earlier that year in the negotiations that led to [[JPMorgan Chase]]'s purchase of [[Bear Stearns]], according to the [[Frontline|PBS Frontline]] introduction to two interviews he gave on December 1, 2011 and December 29, 2012.[^36]
### The Epstein Record
A Justice Department release of Jeffrey Epstein's email includes a message of July 24, 2017 from [[Barry J. Cohen]] to Epstein, subject "S&C: Leon Black Estate Planning," forwarding a "Privileged & Confidential" memorandum on "Leon Black Estate Planning" that Charles T. Dowling of Sullivan & Cromwell had sent on July 12, 2017 to [[Ada Clapp]] and two others. Cohen's covering note read: "Let us know what issues you have."[^37]
### FTX
According to the sworn declaration of its partner [[Andrew G. Dietderich]], the firm was engaged by the FTX group "for a limited number of matters prior to the Petition Date, chiefly with respect to acquisition transactions and specific regulatory inquiries relating to certain U.S. business lines," for total fees and expenses of 8,564,487.50 dollars from July 2021 to the petition date of November 11, 2022, and was "not primary external counsel to any Debtor." The United States Trustee noted that [[Ryne Miller]], general counsel of the FTX US entity, was "a partner at S&C until about 14 months before the filing" and had been an S&C partner "of eight years."[^38][^39]
In the ninety days before the petition the debtors, or others for them, paid the firm 23,882.50 dollars on August 26, 2022; 81,665 dollars on September 6; 142,611.53 dollars on October 5; 195,484.33 dollars on October 19; 166,493.75 and 555,030.05 dollars on October 20; and 2,253,670.77 dollars on November 3. A 12 million dollar retainer was "funded by Debtor [[West Realm Shires Inc.]]" before the petition, and at the petition date the firm held 8,971,661.14 dollars of it as an evergreen retainer. Partner rates in the application ran from 1,575 to 2,165 dollars an hour.[^38]
Schedule 3 to [[Dietderich]]'s declaration listed "Samuel Bankman-Fried" as a former client, with the note "Transactional work arranged for and paid by Debtor [[Alameda Research]] Ltd. (total historical fees $195,000)," and [[Nishad Singh]] as a former client for 23,882.50 dollars. Schedule 2 listed as current clients, among others, [[BlockFi]], [[Coinbase]], [[Gemini]], [[Kraken]], [[Sequoia Capital]], [[Ribbit Capital]], [[Anchorage]], [[Consensys]], [[Bank of America]], [[Morgan Stanley]], [[HSBC]], [[Wells Fargo]], [[UBS]], [[Major League Baseball]], and the ultimate parents of JPMorgan Chase Bank and [[Silicon Valley Bank]].[^4]
[[Warren Winter]]'s amended objection and the declaration of [[Daniel Friedberg]], the former FTX chief regulatory officer, alleged conflicts. Friedberg swore that Miller "informed me that it was very important for him personally to channel a lot of business to S&C as he wanted to return there as a partner after his stint at the Debtors." The Trustee's objection of January 13, 2023 sought a supplemental disclosure. On January 20, 2023 Judge [[John T. Dorsey]] ruled: "there's nothing in the record before me to indicate that ... any investigation would be required of those transactions with which Sullivan & Cromwell might have been involved," found that any potential conflict was met by the debtors' conflicts counsel, and approved the retention.[^39][^40]
On January 19, 2024 the [[United States Court of Appeals for the Third Circuit]] reversed the denial of the Trustee's motion for an examiner; [[James L. Bromley]] and [[Brian D. Glueckstein]] of Sullivan & Cromwell appeared for the debtors.[^40] The examiner, [[Robert J. Cleary]], reported on September 25, 2024 on the firm's representation of Bankman-Fried in his purchase of about 500 million dollars of [[Robinhood]] shares. The representation ran from April 14 to August 5, 2022, was led by the firm's [[Joseph Hearn]] and [[Eric Queen]] under the partner [[Mitch Eitel]], and began with an email from Miller of April 14, 2022 under the subject line "Sam trading question." Cleary found that the firm "provided regulatory advice to Bankman-Fried in his personal capacity" and "did not serve as [[Emergent Fidelity Technologies|Emergent]]'s counsel," that it had no disqualifying conflict, and that it "did not obtain actual knowledge of, or ignore any red flags suggesting, fraud or malfeasance."[^41]
The fee examiner's report of September 5, 2024 recorded that the firm sought 26,877,397.90 dollars in fees and 98,979.37 dollars in expenses for February 1 to April 30, 2024, and listed among areas of concern "too many attorneys billing to monitor the Bankman-Fried sentencing proceedings, and work related to the firm's own defense in the FTX multidistrict litigation pending in the [[United States District Court for the Southern District of Florida|Southern District of Florida]]." *Garrison v. Sullivan & Cromwell LLP*, No. 1:24-cv-20630 (S.D. Fla.), a putative class action by investors, was filed on February 16, 2024; the firm moved to dismiss on May 13, 2024, and the plaintiffs' lawyer said in October 2024 that after the examiner's second report there were "no claims at this stage."[^42][^43]
### Footnotes
[^1]: Partnership Agreement of Sullivan & Cromwell, as of October 1, 1979, Appendix 1, reproduced in Frank Lipsius and Nancy Lisagor, *A Law Unto Itself: The Untold Story of the Law Firm Sullivan & Cromwell* (William Morrow, 1988), p. 313 ("founded by Algernon Sydney Sullivan and William Nelson Cromwell on April 2, 1879"). https://archive.org/details/alawuntoitselftheuntoldstoryofthelawfirmofsullivan
[^2]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 99 to 101 (Victor's death in May 1926, the directorate, Allen Dulles starting in October 1926, "In 1927 Dulles became sole managing partner"), and p. 203 (both brothers entering the Eisenhower administration in 1953).
[^3]: Stephen Kinzer, *The Brothers: John Foster Dulles, Allen Dulles, and Their Secret World War* (Times Books, 2013), ch. 6 (United Fruit; American and Foreign Power; International Railways of Central America; the Schroder Banking Corporation as financial agent; Thomas McCann quoting Sam G. Baggett; the 1936 Ubico agreement). https://archive.org/details/the-brothers-john-foster-dulles-allen-dulles-and-their-secret-world-war-stephen-kinzer
[^4]: Declaration of Andrew G. Dietderich, Exhibit C to the Debtors' Application to Retain Sullivan & Cromwell LLP, D.I. 270-3, Schedules 2 and 3, *In re FTX Trading Ltd.*, No. 22-11068 (JTD) (Bankr. D. Del., filed December 21, 2022), pp. 30 to 37. https://storage.courtlistener.com/recap/gov.uscourts.deb.188450/gov.uscourts.deb.188450.270.3.pdf
[^5]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 50 to 51 (Cromwell's bill for 800,000 dollars, the French arbitration and Poincare; Cromwell as Panamanian general counsel and fiscal agent).
[^6]: *The Story of Panama: Hearings on the Rainey Resolution before the Committee on Foreign Affairs of the House of Representatives* (Government Printing Office, 1913), statement of Henry T. Rainey, pp. 72 to 73; statement of Henry N. Hall, pp. 157 to 158 and 506 to 507; the Sullivan & Cromwell brief to the arbitrators as printed in the record; and Philippe Bunau-Varilla's statement in reply bound with the volume. https://archive.org/details/storypanamahear00bunagoog
[^7]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 62 to 64; Kinzer, *The Brothers*, ch. 1 (Robert Lansing, the "Uncle Bert" of the brothers, later Secretary of State).
[^8]: Kinzer, *The Brothers*, ch. 2.
[^9]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 95 to 96.
[^10]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 132 to 134 (the "Heil Hitler" cables, Allen Dulles's June 1935 visit, the partners' meeting, Dean's remark and denial, the date of closing).
[^11]: John Robinson Beal, *John Foster Dulles: A Biography* (Harper, 1957), quoted in "What The New Biography of Dulles Discreetly Left Out," *I.F. Stone's Weekly,* April 22, 1957, vol. 5, no. 16, p. 1. https://archive.org/details/sim_i-f-stones-bi-weekly_if-stones-weekly_1957-04-22_5_16
[^12]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 141 to 142 (disbanding of Albert & Westrick; Albert's appointment at Ford in 1936; Albert's December 1939 letter; Lamont's death on May 27, 1940).
[^13]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 124 to 125.
[^14]: Lipsius and Lisagor, *A Law Unto Itself*, p. 139.
[^15]: Kinzer, *The Brothers*, ch. 4 (the special election of November 8, 1949).
[^16]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 143 to 144.
[^17]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 153 to 158.
[^18]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 202 to 204.
[^19]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 203 to 205 and 208.
[^20]: *Amendments to the Trading with the Enemy Act,* Hearings before a Subcommittee of the Committee on the Judiciary, United States Senate, 83d Cong., 1st sess., July 20, 21 and 22, 1953 (Government Printing Office, 1953), statement of Ernest K. Halbach, pp. 281 to 282. https://archive.org/details/sim_united-states-congress-hearings-prints-and-reports_july-20-21-and-22-1953
[^21]: *Return of Confiscated Property,* Hearings before a Subcommittee of the Committee on the Judiciary, United States Senate, 83d Cong., 2d sess., on S. 3423, July 1 and 2, 1954 (Government Printing Office, 1954), statement of Cecil Sims, pp. 124 to 125, and the memorandum in opposition that follows it; statement of John Foster Dulles, July 2, 1954, pp. 159 to 162. https://archive.org/details/sim_united-states-congress-hearings-prints-and-reports_july-1-2-1954_0
[^22]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 208 to 210.
[^23]: "Issue on Guatemala," *I.F. Stone's Weekly,* June 21, 1954, vol. 2, no. 22, p. 1. https://archive.org/details/sim_i-f-stones-bi-weekly_if-stones-weekly_1954-06-21_2_22
[^24]: Kinzer, *The Brothers*, chs. 6 and 7 ("On June 27 the commanders gave Arbenz what one called a 'final ultimatum.'").
[^25]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 210 to 211.
[^26]: Kinzer, *The Brothers*, ch. 5 (Schroder as financial agent for Anglo-Iranian; Chase Manhattan as a client of the firm).
[^27]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 214 to 216.
[^28]: Lipsius and Lisagor, *A Law Unto Itself*, pp. 249 to 250.
[^29]: Landmark Legal Foundation, "In Memoriam: William Bradford Reynolds," 2019 ("Brad started his legal career in 1967 with the New York City Law Firm of Sullivan & Cromwell, where he practiced for three years before joining the U.S. Department of Justice in 1973"). https://landmarklegal.org/in-memoriam-william-bradford-reynolds/
[^30]: PayPal, Inc., Form S-1, filed September 28, 2001, "Management." https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
[^31]: Affirm Holdings, Inc., Form S-1 registration statement, filed November 18, 2020, "Management." https://www.sec.gov/Archives/edgar/data/1820953/000110465920126927/tm2026663-4_s1.htm
[^32]: U.S. Securities and Exchange Commission, "Jay Clayton," SEC Historical Summary of Chairmen and Commissioners. https://www.sec.gov/about/sec-commissioners/sec-historical-summary-chairmen-commissioners/jay-clayton
[^33]: Apollo Global Management, Inc., Form 8-K, March 22, 2021, Exhibit 99.1, "Marc Rowan Assumes Role of CEO of Apollo; Jay Clayton Named Non-Executive Chair of Board" ("former SEC Chairman and Apollo's Lead Independent Director Jay Clayton has been named Non-Executive Chairman ... Rowan and Clayton succeed Apollo Founder Leon Black"). https://www.sec.gov/Archives/edgar/data/1411494/000119312521088432/d114836dex991.htm
[^34]: United States District Court for the Southern District of New York, press advisory, August 18, 2025 (appointment under 28 U.S.C. 546(d) effective August 20, 2025). https://www.nysd.uscourts.gov/sites/default/files/2025-08/Press%20Advisory.pdf ; Jenna McLaughlin, "Senate confirms Jay Clayton as director of national intelligence," *NPR,* July 29, 2026. https://www.npr.org/2026/07/29/nx-s1-5910749/senate-confirms-jay-clayton-as-director-of-national-intelligence
[^35]: U.S. Attorney's Office, Southern District of New York, "Meet the U.S. Attorney," accessed October 1, 2026. https://www.justice.gov/usao-sdny/meet-us-attorney
[^36]: "Rodgin Cohen," *The Financial Crisis: The FRONTLINE Interviews,* PBS, interviews of December 1, 2011 and December 29, 2012. https://www.pbs.org/wgbh/pages/frontline/oral-history/financial-crisis/rodgin-cohen
[^37]: U.S. Department of Justice, Epstein Library, EFTA00702518, DataSet 9, email from Barry J. Cohen to Jeffrey Epstein, "S&C: Leon Black Estate Planning," July 24, 2017. https://www.justice.gov/epstein/files/DataSet%209/EFTA00702518.pdf
[^38]: Debtors' Application for an Order Authorizing the Retention and Employment of Sullivan & Cromwell LLP, D.I. 270, paras. 13 to 14, and Declaration of Andrew G. Dietderich, D.I. 270-3, para. 16, *In re FTX Trading Ltd.*, No. 22-11068 (JTD) (Bankr. D. Del., filed December 21, 2022). https://storage.courtlistener.com/recap/gov.uscourts.deb.188450/gov.uscourts.deb.188450.270.0.pdf
[^39]: Objection of the United States Trustee, D.I. 496 (January 13, 2023), pp. 2 to 4; Amended Objection of Warren Winter, D.I. 459 (January 10, 2023); Declaration of Daniel Friedberg, D.I. 530 (January 19, 2023), paras. 13 to 17. https://storage.courtlistener.com/recap/gov.uscourts.deb.188450/gov.uscourts.deb.188450.496.0.pdf
[^40]: Transcript of hearing of January 20, 2023, D.I. 558, pp. 48 to 51, *In re FTX Trading Ltd.*, No. 22-11068 (JTD); *In re FTX Trading Ltd.*, No. 23-2297 (3d Cir. Jan. 19, 2024) (precedential). https://www2.ca3.uscourts.gov/opinarch/232297p.pdf
[^41]: Phase II Report of Robert J. Cleary, Examiner, D.I. 25679 (September 25, 2024), Executive Summary and pp. 11 to 28. https://storage.courtlistener.com/recap/gov.uscourts.deb.188450/gov.uscourts.deb.188450.25679.0.pdf
[^42]: Fee Examiner's Summary Report on Fee Review Process and Sixth Interim Fee Applications, D.I. 24274 (September 5, 2024), pp. 4 to 5 and Exhibit A. https://storage.courtlistener.com/recap/gov.uscourts.deb.188450/gov.uscourts.deb.188450.24274.0.pdf
[^43]: *Garrison v. Sullivan & Cromwell LLP,* No. 1:24-cv-20630 (S.D. Fla.), motion to dismiss, ECF No. 8 (May 13, 2024), https://www.courtlistener.com/docket/68261002/garrison-v-sullivan-cromwell-llp/ ; "FTX investors halt lawsuit against law firm Sullivan & Cromwell," *Lawyer Monthly,* October 2024, https://www.lawyer-monthly.com/2024/10/ftx-investors-halt-lawsuit-against-law-firm-sullivan-cromwell/