02 28 2012 02 28 2012 

UNITED STATES OF AMERICA 


BEFORE THE FEDERAL TRADE COMMISSION 


In the Matter of 

McWANE, INC.,

 a corporation, and 

PUBLIC 

Docket No. 9351 

STAR PIPE PRODUCTS, LTD.,

 a limited partnership. 

Star Pipe Products, Ltd.’s Notice to McWane, Inc. of Stay and Withdrawal from 


Adjudication, and Objections to Pending Discovery Requests 


On February 23, 2012, the Federal Trade Commission issued its Order Withdrawing 

Matter from Adjudication as to Respondent Star Pipe Products, Ltd., for the Purpose of 

Considering a Proposed Consent Agreement. Pursuant to that order and Rule 3.25(c) and (e) of 

the FTC Rules of Practice, 16 C.F.R. § 3.32(c), (e), all proceedings in this matter relating to Star 

Pipe Products, Ltd. (“Star”) have been withdrawn from adjudication and are considered to be in a 

non-adjudicative and stayed status as to Star. 

Star gives notice of these developments because McWane previously served certain 

written discovery requests on Star as a co-respondent, consisting of a First Set of Requests for 

Admissions, a First Set of Requests for the Production of Documents, and a First Set of 

Interrogatories. McWane also served notices for the depositions of 22 individuals at Star. In 

order to avoid any ambiguity and to preserve the stay of proceedings against Star, Star hereby 

files this objection to all of McWane’s written discovery requests and deposition notices, as 

those constitute discovery procedures applicable only to parties to the proceeding. In accordance 

with the FTC’s February 23, 2012 stay of all proceedings involving Star, and the specific rules 

governing the types of discovery requests served by McWane, Star has no duty during the stay to 

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respond to McWane’s written discovery requests and deposition notices, and Star and Star’s 

personnel will be honoring the stay order. 

Dated: February 27, 2012 

 Respectfully submitted, 

/s/ Gregory S. C. Huffman 

Gregory S. C. Huffman 

William M. Katz, Jr. 

Nicole L. Williams 

Brian W. Stoltz 

Thompson & Knight LLP 

1722 Routh Street, Suite 1500 

Dallas, Texas 75201 

(214) 969-1700 

fax: (214) 969-1751 

gregory.huffman@tklaw.com 

william.katz@tklaw.com 

nicole.williams@tklaw.com 

brian.stoltz@tklaw.com 

Attorneys for Star Pipe Products, Ltd. 

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Certificate of Service and Regarding Electronic Submission 

I certify that on February 27, 2012, I filed the foregoing document electronically in PDF 

format using the FTC’s E-Filing System, and also served a copy of the foregoing document on 

the following by the method indicated: 

Joseph A. Ostoyich Edward Hassi 


Andreas Stargard Geoffrey M. Green 


Baker Botts L.L.P. Linda Holleran 


1299 Pennsylvania Ave., N.W. Thomas H. Brock 


Washington, D.C. 20004-2420 Michael L. Bloom
 

Jeanine K. Balbach 

J. Alan Truitt J. Alexander Ansaldo 

Thomas W. Thagard III Bureau of Competition 

Maynard Cooper & Gale PC Federal Trade Commission 

1901 Sixth Avenue North Washington, DC 20580

2400 Regions Harbert Plaza 

Birmingham, AL 35203 Complaint Counsel 

(by email to ehassi@ftc.gov)

Counsel for McWane, Inc. 

(by email to 

joseph.ostoyich@bakerbotts.com) The Honorable D. Michael Chappell 

Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-106 

Washington, DC 20580 

(by email to oalj@ftc.gov and by Federal 

Express) 

I also certify that the electronic PDF copy of the foregoing document sent to the 

Secretary of the Commission via the FTC E-Filing System is a true and correct copy of the 

original in my possession, which is available for review by the parties and the adjudicator. 

/s/ Brian W. Stoltz 

Brian W. Stoltz 

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