: It,
Dated: November /F, 2008 By Darrius Cobos ee [ yun

Darius Ogloza

LATHAM & WATKINS LLP

505 Montgomery Street, Suite 2000
San Francisco, California 94111-6538
Telephone: +1.415.391.0600
Facsimile: +1.415.395.8095
hanno.kaiser@lw.com*

darius.ogloza@lw.com
* Admitted in New York only.
Not admitted in California.

Attorneys for ENTEK International LLC

SF\679176.2 11-17-2008PPAB 1503492v1


CERTIFICATE OF SERVICE

1am employed in the District of Columbia, D.C. I am over the age of 18 and not a party
to the within cause. My business address is Latham & Watkins LLP, 555 Eleventh Street, N.W., Suite
1000, Washington, D.C. 20004-1304.

On November 17th, 2008, I served the following document described as:

STIPULATION AND [PROPOSED] ORDER REGARDING
DISCOVERY RELATED TO ENTEK INTERNATIONAL LLC

by serving a copy of the above-described document in the following manner:

__BY MESSENGER SERVICE

Tplaced a sealed envelope or package, addressed as follows:

Donald S. Clark, Secretary The Honorable D. Michael Chappell
Office of the Secretary Administrative Law Judge

Federal Trade Commission Federal Trade Commission

600 Pennsylvania Avenue, NW,Rm. 600 Pennsylvania Avenue, NW
H-135 Washington, DC 20580

Washington, DC 20580
(2 copies)
(original and 12 copies)

I caused such envelope or package to be delivered by messenger to the offices of the
addresses.

I declare that I am employed in the office of a member of the Bar of or permitted to
practice before this court at whose direction the service was made.

Executed on November 17, 2008, at Washington, D.C.

SONIA NATH


UNITED STATES OF AMERICA
BEFORE THE FEDERAL TRADE COMMISSION

In the Matter of CASE NO. 9327

Polypore International, Inc.
a corporation. PUBLIC DOCUMENT

CERTIFICATE OF SERVICE


Dated: November !7, 2008 AL
By 56

J. Robert Robertson

Federal Trade Commission
600 Pennsylvania Avenue, NW
Washington, DC 20580

rrobertson@ftc.gov
Complaint Counsel

IT IS SO ORDERED.

D. Michael Chappell
Administrative Law Judge

SF679176.2 11-17-2008PPAB 1503492v1



William L. Rikard, Jr. Eric D. Welsh

Parker Poe Adams & Bernstein LLP Parker Poe Adams & Bernstein LLP
Three Wachovia Center Three Wachovia Center

401 South Tyson St., Suite 3000 401 South Tyson St., Suite 3000
Charlotte, NC 28202 Charlotte, NC 28202
williamrikard@parkerpoe.com ericwelsh@parkerpoe.com

(1 copy) (1 copy)

I declare that I am employed in the office of a member of the Bar of, or permitted
to practice before, this Court at whose direction the service was made and declare under penalty
of perjury under the laws of the State of California that the foregoing is true and correct.

Executed on November 17, 2008, cs9 ca )
Mh Aah
Ce ]

Beth A. Davis


ORIGINAL

UNITED STATES OF AMERICA
BEFORE THE FEDERAL TRADE COMMISSION

In the Matter of CASE NO. 9327

Polypore International, Inc.
a corporation. PUBLIC DOCUMENT

STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY
RELATED TO ENTEK INTERNATIONAL LLC

WHEREAS, the Federal Trade Commission (“Commission”) provided notice,

_ dated October 27, 2008, that it intended to produce all of ENTEK International LLC’s
(“ENTEK”) documents produced pursuant to the Civil Investigative Demand and Subpoena
Duces Tecum issued by the Commission (“CID”), dated April 10, 2008, to Polypore
International, Inc. (“Polypore”);

WHEREAS, ENTEK filed its Motion for Protective Order Pursuant to 15 U.S.C.
§§ 15 U.S.C. §§46(f), 57b-2(d)(1)(C) and 57b-2(d)(2), and 16 C.F.R. §4.10 (“Motion for
Protective Order”), seeking an order directing the Commission to withhold production of
ENTEK’s documents pending implementation of certain procedures designed to protect from
disclosure ENTEK’s highly confidential information;

WHEREAS, on November 6, 2008, subsequent to the filing of ENTEK’s Motion
for Protective Order, Polypore served a Subpoena Duces Tecum on ENTEK seeking the
production of documents responsive to forty (40) specifications, including the documents which
are the subject of ENTEK’s Motion for Protective Order, on or by November 24, 2008

(“Polypore Subpoena”); and

SF\679176.2 11-17-2008PPAB 1503492v1


CERTIFICATE OF SERVICE

I am employed in the County of San Francisco, State of California. I am over the
age of 18 years and not a party to this action. My business address is Latham & Watkins LLP,
505 Montgomery Street, Suite 2000, San Francisco, CA 94111-6538.

On November 17, 2008, I served the following documents described as:

STIPULATION AND [PROPOSED] ORDER REGARDING
DISCOVERY RELATED TO ENTEK INTERNATIONAL LLC

by serving a true copy of the above-described documents in the following manner:

BY ELECTRONIC MAIL

The above-described document was transmitted via electronic mail to the following party
on November 17, 2008:

Donald S. Clark, Secretary The Honorable D. Michael Chappell
Office of the Secretary Administrative Law Judge

Federal Trade Commission Federal Trade Commission
secretary@ftc.gov oalj@fic.gov

Robert Robertson, Esq. J. Steven Dahm, Esq.

Federal Trade Commission Federal Trade Commission
rrobertson@ftc.gov sdahm@ftc.gov

William L. Rikard, Jr. Eric D. Welsh

Parker Poe Adams & Bernstein LLP Parker Poe Adams & Bernstein LLP
williamrikard@parkerpoe.com ericwelsh@parkerpoe.com

The party on whom this electronic mail has been served has agreed in writing to such form of
service pursuant to agreement.

BY OVERNIGHT MAIL DELIVERY

I am familiar with the office practice of Latham & Watkins LLP for collecting
and processing documents for overnight mail delivery by Express Mail or other express service
carrier. Under that practice, documents are deposited with the Latham & Watkins LLP personnel
responsible for depositing documents in a post office, mailbox, subpost office, substation, mail
chute, or other like facility regularly maintained for receipt of overnight mail by Express Mail or
other express service carrier; such documents are delivered for overnight mail delivery by
Express Mail or other express service carrier on that same day in the ordinary course of business,
with delivery fees thereon fully prepaid and/or provided for. I deposited in Latham & Watkins
LLP?’ interoffice mail a sealed envelope or package containing the above-described document
and addressed as set forth below in accordance with the office practice of Latham & Watkins
LLP for collecting and processing documents for overnight mail delivery by Express Mail or
other express service carrier:

Robert Robertson, Esq. J. Steven Dahm, Esq.

Federal Trade Commission Federal Trade Commission
600 Pennsylvania Avenue, NW 600 Pennsylvania Avenue, NW
Washington, DC 20580 Washington, DC 20580

(1 copy) (1 copy)


Dated: November/7, 2008
oy GeO bh —

Eric. D. Welsh

PARKER POE ADAMS & BERNSTEIN,
LLP

Three Wachovia Center

401 South Tryon Street, Suite 3000
Charlotte, NC 28202

Telephone: (704) 372-9000

Facsimile: (704) 335-9689
ericwelsh@parkerpoe.com

Attorneys for Respondent

$F\679176.2 11-17-2008PPAB 1503492v1


Order, its demand that the Commission produce ENTEK documents in its possession as a result
of the CID;

3. Polypore agrees to continue the date and time for the filing of any motion
seeking to quash or limit the Polypore Subpoena until five (5) business days after the parties
determine in good faith that they will not be able to resolve all discovery issues and disputes
raised in connection with the Polypore Subpoena;

4, ENTEK agrees to limit any motion seeking to quash or limit the Polypore
Subpoena solely to those issues that remain unresolved between the Parties and to produce to

Polypore in a timely manner documents as to which no objection remains unresolved.

By executing this Stipulation and Order, Complaint Counsel acknowledges that it
has received notice of the recitals and stipulations set forth herein and confirms that it has no
objection to any of its terms and that it shall refrain from producing to Polypore ENTEK
documents produced to it pursuant to the CID until such time as it is directed to do so by order of

the tribunal or by direction of both Parties hereto.

SF\679176.2 11-17-2008PPAB 1503492v1


WHEREAS, to enhance efficiency and, thereby, to conserve private and
administrative agency resources, counsel for Polypore and ENTEK have agreed to enter into this
stipulation and order (“Stipulation and Order”) to attempt in good faith to resolve all discovery
issues and disputes that have arisen between them in the above matter;

IT IS HEREBY STIPULATED, by and between counsel for Polypore and counsel
for ENTEK:

1. Polypore hereby agrees and consents to stay indefinitely its demand that
the Commission produce ENTEK documents in the Commission’s possession as a result of the
CID; provided, however, that nothing in this Stipulation and Order shall be deemed a waiver of
any right of Polypore, including its right to seek production of such discovery from ENTEK
through the Polypore Subpoena or through reinstatement of such demand on the Commission in
the event the Parties hereto are unable to resolve any discovery issues and disputes raised in
connection with the Polypore Subpoena; it being further understood and agreed that if Polypore
reinstates its demand on the Commission to produce ENTEK documents in its possession as a
result of the CID, with same day email copy to the undersigned counsel for ENTEK, Polypore
shall have five (5) business days from written reinstatement of its demand to the Commission to
file and serve any opposition or response to ENTEK’s Motion for Protective Order;

2. ENTEK hereby agrees and consents to withdraw its Motion for Protective
Order, pursuant to the terms of this Stipulation and Order; provided, however, that nothing in this
Stipulation and Order shall be deemed a waiver of any right of ENTEK, including its right to
seek relief in the context of any subsequent motion to quash or for protective order with respect
to the Polypore Subpoena, and/or to seck such relief through the Motion for Protective Order,
which shall be deemed reinstated without requiring any further action on ENTEK’s part in the

event Polypore shall renew or reinstate, at any time after the effective date of this Stipulation and

SF\679176.2 11-17-2008PPAB 1503492v1