Areas of Practice
Unlike many attorneys, Bill does not expect repeat business. Clients he works with are usually facing the kinds of high-stakes, high-stress problems that are not likely to recur - a financial services company under SEC investigation, a hospital accused of Medicare fraud, or a C-suite executive charged with fraud or insider trading. These clients turn to Bill to address and resolve the issues, while minimizing the impact to their businesses and reputations.
Bill has long been a white collar trial lawyer with a particular focus on healthcare fraud and securities enforcement. A former prosecutor at the highest levels of the Department of Justice, Bill was responsible for all the Department’s white collar operations, as well as the day-to-day workings of its corporate fraud task force. He also served as Special Counsel for Health Care fraud overseeing all of the Department’s health care fraud enforcement. This experience makes him unusually adept at handling the collateral consequences of white collar matters, which can occur in any of four separate legal forums - criminal, civil, administrative, and regulatory - sometime all at once.
Bill has a deep understanding of each of these forums, and he regularly demonstrates that “the best defense is a good prosecutor.” He maintains strong relationships in U.S. Attorney’s Offices around the country, as well as at the SEC and various state and federal enforcement agencies nationwide. The benefit to clients is that Bill not only thinks like a prosecutor, but at times, he is a contemporary to the prosecutor or investigating attorney assigned to his case. His goal in every matter is to see that business continues with the least amount of disruption, and that each individual receives not only an aggressive defense, but one that is acceptable and comfortable for the client.
•Senior Counsel to Deputy Attorneys General, Larry Thompson and James Comey, Office of the Deputy Attorney General, U.S. Department of Justice (Washington, D.C., 2003-2004)
•Point Person, President George W. Bush’s Corporate Fraud Task Force
•DOJ Special Counsel for Health Care Fraud
•National oversight over and coordination of the Department of Justice’s, (1) white collar functions, including health care enforcement, (2) relationship with the U.S. Sentencing Commission and matters relating to the U.S. Sentencing Guidelines, and (3) efforts to combat violent crime, including oversight over the Bureau of Alcohol, Tobacco and Firearms and Project Safe Neighborhoods
•Counsel to the Director, Executive Office for United States Attorneys, U.S. Department of Justice (Washington, D.C., 2002-2003)
•Legal Evaluator, Executive Office of U.S. Attorney’s Evaluation and Review Staff (2000-2004) Assistant U.S. Attorney, Northern District of Texas, U.S. Department of Justice (1991-2004)
•D CEO Magazine's 500 Most Powerful Business Leaders in Dallas-Fort Worth, 2017 and 2018
•D CEO Magazine's Dallas 500 Law - White Collar Criminal Defense in Dallas-Fort Worth, 2016
•Texas Tech School of Law 2016 Distinguished Alumni Award
•White Collar Crime Trailblazers of 2015, National Law Journal
•Texas Super Lawyers, Texas Monthly, 2006-2018
•Best Lawyers in Dallas, Criminal Defense: White CollarD Magazine, 2008-2019
•Best Lawyers in Dallas, Criminal Defense: White CollarD Magazine, 2009
•The Best Lawyers in America , Commercial Litigation, 2010, 2017-2019
•The Best Lawyers in America , White Collar Litigation, 2011
•The Best Lawyers in America , Litigation - Regulatory Enforcement (SEC, Telecom, Energy), 2012-2019
•The Best Lawyers in America , Litigation - Securities, 2014-2019
•Honorary Special Agent, Department of Treasury Inspector General for Tax Administration, 2003
•Certificate of Appreciation, Texas Comptroller of Public Accounts, Criminal Investigative Division, 2003
•Director’s Award for Superior Performance as an Assistant U.S. Attorney, Executive Office for United States Attorneys, 2001
•Merit Award, Bureau of Alcohol, Tobacco and Firearms, 2000
•Merit Award, Bureau of Alcohol, Tobacco and Firearms, 1998
•Director’s Award, Texas Department of Public Safety, 1998
•Honorary Special Agent, Criminal Investigation Division of Internal Revenue Service, 1998
•Currently representing Texas’ Attorney General in connection with a state criminal securities fraud prosecution.
•Successfully represented Missouri's former governor in connection with a federal investigation regarding unsubstantiated allegations of political patronage
•Successfully represented multiple individuals and companies in connection with various SEC insider trading, accounting fraud, and other investigations
•Conducted tens of corporate internal investigations involving subjects as varied as vendor kickback schemes, illegal bribes and gratuities, Foreign Corrupt Practices Act, and insider trading by a company’s chief executive officer.
•Conducted the internal investigation of a Chief Compliance Officer of a national health care provider who intended to be a whistleblower under the False Claims Act.
•Successfully represented numerous companies and individuals in connection with federal and state whistleblower lawsuits and resulting civil and criminal investigations conducted by HHS-OIG, the FBI, U.S. Attorney’s Offices, and state Medicaid officials.
•Successfully represented numerous individual healthcare providers in indicted criminal cases, federal and state healthcare fraud investigations, and matters before state medical boards.
•Made numerous criminal referrals to prosecutors and regulatory agencies in matters involving trade secret theft, embezzlement, dealing with prohibited countries, money laundering, and other alleged criminality.
•Successfully represented multiple oil and gas promoters before federal and state securities regulators to beat back charges that their sponsored joint ventures constituted “securities” under federal and state law.
•Successfully represented multiple physician and dental practice groups in connection with numerous Medicare and Medicaid fraud investigations.
•Successfully represented multiple healthcare providers and DME/pharma interests in Anti-Kickback, Stark Act, off-label promotion and False Claims Act investigations and cases.
•Successfully represented multiple companies civilly and criminally in connection with a departing employee’s alleged theft of corporate trade secrets.
•Obtained the dismissal of a state securities fraud case against a University of Texas professor
•Obtained a deferred prosecution of $900 million window and door manufacturer in connection with an ICE worksite enforcement prosecution; obtained dismissal of restaurant manager in federal criminal case involving allegations of hiring of illegal aliens.
•Successfully represented a major, publicly-traded medical provider and leading home- and community-based service provider to the mentally ill in a joint federal/state whistleblower lawsuit alleging millions of dollars in damages.
•Counseled numerous companies on compliance with the Foreign Corrupt Practices Act and federal export laws.
•Counseled numerous companies on compliance with the Heath Insurance Portability and Accountability Act (HIPAA).
•Represented a West Texas agribusiness in a major criminal and civil False Claims Act prosecution and investigation.
•Represented the former chairman of the board of a publically traded company before the Delaware Chancery Court in a shareholder derivative action.
•Served as a AAA arbitrator in two arbitrations, one of which was an arbitration involving a hospital and claims administrator.
•Successfully represented a $900 million manufacturing concern in connection with parallel criminal and SEC investigations involving allegations of accounting fraud and self-dealing.
•Represented significant business concerns in connection with insurance coverage disputes
•Represented Innovation First, Inc., in suing the Dominion Multiple Employer Welfare Benefit Trust and American General Life Insurance Company, among others, in connection with Innovation First’s participation in the Trust.
•Counseled a debt consolidation business on compliance matters, including compliance with various FTC regulations.
•Represented a money transmitting business in a federal unlicensed money transmitting business prosecution.
•Represented an individual before DOJ’s Office of Pardon Attorney and in connection with his application for a federal pardon.
•Successfully represented multiple individuals in connection with mortgage fraud investigations and prosecutions.
•Counseled significant life insurance company on anti-money laundering and OFAC compliance.
•Making The Granston Memo Work For FCA Defendants
Law360 , March 4, 2019
•SCOTUS Limits Disgorgement: What It Means for Sam Wyly and Other Defendants
The Texas Lawbook , June 27, 2017
•SEC Takes Aim at Anti-Whistleblower Employment Agreements
The Texas Lawbook , September 13, 2016
Government Contracts, Investigations & International Trade Blog Posts
• Fool Me Twice...SEC’s latest Cyber-Fraud ROI Indicates Future Enforcement Against Hacker Victims, November 28, 2018
• Kickbacks Aren’t Illegal Just for Federal Health Care Programs in Recently Enacted SUPPORT Act: New Compliance Concerns for Physician-Owned Laboratories, November 6, 2018
• Supreme Court Strikes Down Federal Sports Gambling Law, May 16, 2018
•Forest Park Kickback Trial Preview
The Texas Lawbook , February 19, 2019
FOX Nation , February 14, 2019
•Movers & Shakers Feature
The Deal , April 20, 2018
•Sheppard Mullin Enters Texas Market With Dallas Office
Law360 , April 16, 2018
•Sheppard Mullin Officially Opens Dallas Office
The Texas Lawbook , April 16, 2018
•Sheppard Mullin Launches Dallas Office
Texas Lawyer , April 16, 2018
•Comey on Capitol Hill
FOX Business , June 8, 2017
•Trump's FBI Pick is No Lackey, Say Dallas Lawyers Who Worked With Him
Dallas News , June 7, 2017
•Trump's FBI Pick Known As 'Adult In The Room'
Law360 , June 7, 2017
•Who Is Christopher Wray?
The Libertarian Republic , June 7, 2017
•President Trump Nominates Christopher Wray As New FBI Director
NPR , June 7, 2017
•Trump to Nominate Christopher Wray as Next FBI Director
The Washington Post , June 7, 2017
•Speaker, Discovery in Federal Criminal Cases and The Travel Act, Federal White Collar Crime Seminar, Fort Worth, TX, October 5, 2018
•Moderator, Winning In The Courtroom - A Conversation With Dan Cogdell, Dallas Bar Association Trial Skills Section, December 15, 2017
•Co-Presenter, Better to Give Than to Receive: Prosecuting and Defending Bribery and Corruption Cases Post-McDonnell, American Bar Association's Southeastern White Collar Crime Institute, Braselton, GA, September 7, 2017
• Healthcare Fraud Update, ABA White Collar Crime North Texas Subregional Event, February 10, 2017
• Internal Investigations: Best Practices for Preparing for and Responding to Potential Claims, EBEC National Event, Fort Worth, TX, November 10, 2016
• Healthcare Fraud in Payments - An Open Payments & Fraud and Abuse 2016 Mid-Year Review, IMS Health U.S. Transparency Conference; Morristown, NJ, October 6, 2016
• Internal Investigations: Best Practices for Preparing for and Responding to Potential Claims, EBEC National Event, Denver, CO, September 28, 2016
• Forum on U.S. Attorneys, TTU Law School; Lubbock, TX, September 21, 2016
• Evolution of the Dallas-Ft. Worth White Collar Bar as Told by Its Founders, ABA White Collar Crime North Texas Subregional Event, Dallas, TX, September 16, 2016
• From Subpoenas to Search Warrants: What Corporate GCs Need to Know About Criminal Investigations, GC Netweavers; Dallas, TX, September 15, 2016
• Attack on All Fronts: Civil and Criminal Lawyers on DOJ Investigations, Polsinelli Business Law Institute, Chicago, IL, June 14, 2016
• Universal Health Services v. United States ex rel. Escobar, Polsinelli Webinar, Webinar, June 8, 2016
• Top 10 Things on the DOJ and OIG’s Bad List, 2016 Annual Healthcare Dealmakers Conference, Dallas, TX, May 26, 2016
• Parallel Proceedings: What Civil Defense Counsel Need To Know About Title 18 And Other Criminal Law Issues, TADC Winter Seminar; Telluride, CO, January 28, 2016
• What Civil Lawyers Need To Know About Criminal Law, Dallas Bar Association, Trial Skills Section; Dallas, TX, November 17, 2015
• Sez who? SEC Targeting Attorneys Who Allegedly Obstruct Enforcement Investigations, American Bar Association, Ninth Annual Institute on Securities, New Orleans, LA, November 14, 2014
• Recent Trends in Healthcare Enforcement Cases, University of Texas School of Law Government Enforcement Institute, Dallas, TX, May 21, 2014
• Work Site Enforcement/I-9E-Verify for Experts, ILW Webinar, March 13, 2014
• 2014 Insider Trading Update and The Mark Cuban Trial, Houston Bar Association, Securities Litigation and Arbitration Section, Houston, TX Dallas Bar Association Securities Section; Dallas, TX, February 2014
• Federal Jury Trials, Dallas Bar Association, Trial Skills Section, Dallas, TX, November 22, 2013
• Healthcare Fraud Enforcement in North Texas, Dallas Bar Association, Health Law Section, Dallas, TX, November 20, 2013
• Getting to Non-Prosecution: Effective Strategies for Making the Best Case for Individual and Corporate Clients, American Bar Association, Eighth Annual Institute on Securities Fraud, New Orleans, LA, October 24, 2013
• Emily Post for FCPA Prosecutions: How the Prosecution and Defense May Conduct Themselves to the Best Advantage, American Bar Association Criminal Justice Section, Midyear Meeting, Dallas, TX, February 8, 2013
• SEC Jeopardy: Broker Dealers and Investment Advisors in the SEC Gauntlet, American Bar Association Seventh Annual Institute on Securities Fraud, New Orleans, LA, November 15, 2012
• Foreign Corrupt Practices Act - Is The Cover-Up Worse Than The Crime?, State Bar of Texas, Advanced Business Law Conference, Houston, TX, November 1, 2012
• What’s New in the Northern District of Texas: Tips on What To Do and What Not To, Dallas Bar Association Bench Bar Conference, Marble Falls, TX, September 27, 2012
• The Foreign Corrupt Practices Act: More Enforcement Than Ever, State Bar of Texas, Live Webcast, June 6, 2012
• Hey, What About Me? State Securities Regulators, American Bar Association Sixth Annual National Institute on Securities Fraud, New Orleans, LA, November 3, 2011
• Innovative and Cutting Edge Uses of Technology in the Courtroom, Dallas Bar Association Trial Skills Section, Dallas, TX, August 12, 2011
• Foreign Corrupt Practices Act: Managing Your Exposure and Risks, North Texas District Export Council FCPA Conference, Garland, TX, October 13, 2010
• Financial Reforms: Overview of Legislation, Enforcement, and Future Implications, American Bar Association Fifth Annual National Institute on Securities Fraud, New Orleans, LA, October 8, 2010
• Interplay Between Administrative Law and Criminal Law, State Bar of Texas, Advanced Administrative Law Conference, Austin, TX, September 17, 2010
• Insider Trading Knows No Bounds: What Theory Will They Come Up With Next?, American Bar Association Fourth Annual National Institute on Securities Fraud, Washington, DC, October 15, 2009
• A View From the Federal Bench, Dallas Bar Association Bench Bar Conference, Marble Falls, TX, September 24, 2009
• The False Claims Act, Federal Bar Association, Dallas, TX, September 10, 2009
• Foreign Corrupt Practices Act Update: Recent Trends and Developments, State Bar of Texas, Live Webcast, June 16, 2009
• Counseling the General Counsel in Times of Trouble, American Bar Association, National Institute on Internal Corporate Investigations and In-House Counsel, Washington, DC, May 8, 2009
• The Uncertainty Surrounding Honest Services Fraud, American Bar Association Business Law Section, Live Webcast, February 11, 2009
• Foreign Corrupt Practices Act/International Law, Texas Lawyer Roundtable Series, Dallas, TX, December 3, 2008
• Recent Insider Trading Developments, Dallas Bar Association Securities Law Section, Dallas, TX, June 23, 2008
• Caught In The Crosshairs: What Accountants Need To Know About White Collar Crime, Dallas CPA Society Conference, Dallas, TX, May 2, 2008
• Emerging Legal Issues in an Increasingly Diverse Business Environment - Payment to Foreign Officials - Watch Out for Criminal/Civil FCPA Liability, State Bar of Texas Asian Pacific Interest Section - 12th Annual CLE & Retreat, Houston, TX, April 26, 2008
• Corporate Plea Bargaining: Are Deferred Prosecution Agreements for Corporations Better than Pleading Guilty?, 2nd Annual National Institute on White Collar Crime, Miami, FL, March 5-7, 2008
• Enforcement Efforts: SEC and State Targets, University of Texas - 30th Annual Conference on Securities Regulation and Business Law, Dallas, TX, February 7-8 2008
• Securities Fraud: Reigning in the Parade: Aggressive Prosecutorial Tactics and Defensive Countermeasures, American Bar Association, Securities Fraud National Institute, Washington, DC, October 25-26, 2007
• How to Effectively Monitor Internal Communications, HCPro, Inc., Webcast, October 3, 2007
• Suing Gatekeepers - Point/Counterpoint, SEC’s Southwest Securities Conference, Fort Worth, TX, September 6, 2007
• Punish the Bad Apple, or the Whole Bunch?: Corporate Criminal Liability Standards & Tactics, and Theories for a Different Approach, Washington Legal Foundation Webinar, Washington, DC, June 28, 2007
• Help Wanted: General Counsel: Must be able to deal with unlimited converging corporate problems, many of them novel and often of a public nature. “and must possess ability to juggle and perform acrobatic feats.,” State Bar of Texas Annual Meeting, 6th Annual Corporate Counsel Forum, San Antonio, TX, June 22, 2007
• The Second Amendment - The Current State of the Second Amendment, Southern Methodist University School of Law, Dallas, TX, February 26, 2007
• What the Average Practitioner Needs to Know About the Criminalization of Civil Practice, Texas Association of Defense Counsel, South Lake Tahoe, CA, February 1, 2007
• Which Way is Up?, Dallas Federal Bar Association (White Collar Crime Committee), Dallas, TX, September 2006
• Measuring the Explosive Growth of Federal Crime Legislation, The Federalist Society (Texas Tech Chapter), Lubbock, TX, September 2006
• Compliance - Making It or Faking It: How Corporate Culture Affects the Business and Regulatory Environments, American Bar Association, Securities Fraud National Institute, Washington, DC, September 2006
• The Federalist Society - The Conservative Cabal That’s Transforming American Law, Greater Dallas Pachyderm Club, Dallas, TX, September 2006
• Don’t be the Dumbest Guy in the Room: Lessons Learned From Enron, Dallas CPA Society, Dallas, TX, August 2006
• Sources of Attorney Liability - Discussion relating to Common Law - Federal/State Securities Laws: Sarbanes Oxely - Section 307 Update, State Bar of Texas Annual Meeting, Corporate Counsel Forum, Austin, TX, June 2006
• Talking to the Government - or - When, Why, and How to Proffer, National Association of Criminal Defense Lawyers (White Collar Crime Section), Philadelphia, PA, May 2006
• Corporate Death Penalty and Deferred Prosecutions, Federal Bar Association (Criminal Law Section Annual Meeting), New Orleans, LA, May 2006
• Arthur Anderson v. United States: Will the Supreme Court Expand the Criminalization of Business Practices?, Washington Legal Foundation Press Briefing, Washington, DC, April 2006
• Press Freedom and Religious Liberty in America, Third Annual Austin College Law Symposium, Sherman, TX, March 2006
• What the Average Practitioner Needs to Know About the Criminalization of Civil Practice, South Plains Trust and Estate Counsel, Lubbock, TX, February 2006
• Attorney-Client Privilege Waivers in Criminal Investigations, The Federalist Society (Washington, DC Chapter), Washington, DC, January 2006
• Attorney-Client Privilege: Where Do We Go From Here?, U.S. Chamber of Commerce, Washington, DC, November 2005
• SEC Enforcement Actions - What to Expect in an SEC Investigation, American Bar Association, Teleconference, October 2005
• When the Phone Rings at 3AM, State Bar of Texas, 4th Annual Advanced In-House Counsel Institute, San Antonio, TX, October 2005
• The Department of Justice’s Prosecution of Business Entities, American Conference Institute, National Forum on Export Enforcement & Investigations, Washington, DC, October 2005
• The Increased Criminalization of Civil Practice in the Wake of Recent Corporate Fraud Scandals, Amarillo Bar Association, Amarillo, TX, September 2005
• The Criminalization of Civil Practice - What You Need to Know, State Bar of Texas, 28th Annual Civil Trial Course, Austin, TX, August 2005, Dallas, TX, Sept. & Oct. 2005
• Lessons Learned: Corporate Fraud in America 2002-2005, Dallas Bar Association Securities Section, Dallas TX, June 2005
• Defining the Rule of the Corporate Attorney - Government Perspectives, State Bar of Texas Annual Meeting, Corporate Counsel Forum, Dallas, TX, June 2005
• Deferred Prosecution Agreements: Promises and Pitfalls for Business Under the Federal Microscope, Washington Legal Foundation Webcast, Washington, DC, May 2005
• Corporate Liability and Compliance in the Health Care Industry, American Bar Association, Healthcare Fraud Institute, Palm Springs, CA, May 2005
• Got Religion: The Explosion of Religion in the Workplace (and How Employers Should Deal With It, Dallas Human Resource Management Association, Dallas, TX, April 2005
• Lessons Learned: Corporate Fraud in America 2002-2005, Greater Dallas Crime Commission, Dallas, TX, February 2005
• The Intersection of Recent Corporate Fraud Scandals and Internal Investigations, CLE International, Internal Investigations, Dallas, TX, January 2005
•Adjunct Professor, Texas Tech School of Law, 1995-2002, 2006-2012
•American Bar Association, 1986-2000, 2005-present
•Co-Chair, American Bar Association, North Texas-Oklahoma Subcommittee of the Criminal Justice Section's White
•Collar Crime Committee, American Bar Association, 2006-present
•Criminal Justice Section Book Board, American Bar Association, 2013-present
•Criminal Justice Section Upjohn Working Group, American Bar Association, 2008, 2009
•Criminal Justice Section Parallel Proceedings Task Force, American Bar Association, 2010-2012
•Member of Criminal Justice Section, American Bar Association, 2005-present
•Texas Delegate, Young Lawyers Division, American Bar Association, 1996-1999
•American Health Lawyers Association, 2016-present
•Dallas Bar Association, 1986-1991, 2005-present
•Dallas Bar Association, Director, Board of Directors, Dallas Bar Association, 2015-present
•Co-Chair, 2015 Equal Access to Justice Campaign,
•Chair, Trial Skills Section 2011-2012; Immediate Past-Chair 2013-2014, Vice Chair 2009-2010, Dallas Bar Association
•Director, Dallas Bar Association, 2007-present
•Secretary-Treasurer, Dallas Bar Association, 2009-2010
•Co-Chair, Bench Bar Committee, Dallas Bar Association, 2008
•Dallas Bar Foundation, 2006 -present
•Dallas Young Lawyers Foundation, 2005- present
•Lubbock County Bar Association, 1991 -2004
•Lubbock County Defense Lawyers Association, 2010-present
•Health Care Compliance Association, 2010-present
•National Association of Assistant U.S. Attorneys, 1995- 2004
•National Association of Criminal Defense Lawyers, 2005-present
•Vice Chair, White Collar Crime Committee, National Association of Criminal Defense Lawyers, 2006-2008
•Texas Criminal Defense Lawyers Association, 2005-present
•Texas Disciplinary Rules of Professional Conduct Committee, 2006-2009
•Texas Bar Foundation, 1997-present
•Co-Chair, Dallas Nominating Committee, Texas Bar Foundation, 2014-2015
•Board of Trustees, Texas Bar Foundation, 1997-1998
•fellow and Sustaining fellow, Texas Bar Foundation, 1997-present
•Texas Young Lawyers Association, 1986-2000
•Texas Young Lawyers Association, President, 1997-1998; Immediate Past President, 1998-1999; President Elect, 1996- -1997
•Chair, Liberty Bell Committee, Texas Young Lawyers Association, 2000-2001
•Chair, Outstanding Young Lawyer of Texas Committee, Texas Young Lawyers Association, 1999-2000
•Board of Directors, Texas Young Lawyers Association, 1995-1999
•Regional Coordinator for Disaster Legal Services, Texas Young Lawyers Association, 1995-1999
•Texas Tech Law School Foundation, Trustee, 2016-present
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