There is reasonable suspicion, some might argue evidence, that Microsoft voluntarily cooperated with U.S. Intelligence Community without being compelled by a court order, the most famous instances being leaked in the Snowden disclosures.
To be fair to Microsoft, here's their updated statement (emphasis mine):
"Microsoft confirmed to Forbes that it does provide BitLocker recovery keys if it receives a valid legal order. “While key recovery offers convenience, it also carries a risk of unwanted access, so Microsoft believes customers are in the best position to decide... how to manage their keys,” said Microsoft spokesperson Charles Chamberlayne."
