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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

In the Matter of )
 

) Docket No. 9327
 

)
 Polypore International, Inc.
 )


a corporation ) PUBLIC DOCUMENT
 

)
 

RESPONDENT'S CROSS-MOTION TO COMPEL THE MOORE COMPANY TO 

PRODUCE DOCUMENTS REOUESTED BY SUBPOENA DUCES TECUM 

Respondent Polypore International, Inc. ("Polypore") respectfully submits this CrossMotion to Compel The Moore Company To Produce Documents Requested by Subpoena Duces 

Tecum in accordance with Commission Rule § 3.38(a)(2). This motion is based on the grounds 

set forth in the Poylpore's Memorandum in Opposition to the Moore Company's Motion to Limit 

Subpoena Duces Tecum and for Cost Reimbursement and in Response to The Moore Company's 

Motion for In Camera Treatment of Material and in Support of Respondent's Cross-Motion to 

Compel The Moore Company to Produce Documents Requested by Subpoena Duces Tecum filed 

contemporaneously herewith. 

Respondent seeks the immediate production of documents and electronic data responsive 

to its subpoena duces tecum. Counsel for Respondent has conferred with counsel for The Moore 

Company in a good faith effort to reach a resolution on The Moore Company's compliance with 

Respondent's subpoena. Respondent and The Moore Company have been unable to resolve the 

dispute and Respondent therefore respectfully petitions this Cour for an Order requiring 

immediate compliance. 

PPAB lS20233vl 
Dated: January 8, 2009 Respectfully Submitted, 

13'0 Mk/-

Wiliam L. Rikard, Jr. 

Eric D . Welsh 

PARKR POE ADAMS & BERNSTEIN, LLP 

Three Wachovia Center 

401 South Tryon Street, Suite 3000 

Charlotte, NC 28202 

Telephone: (704) 372-9000 

Facsimile: (704) 335-9689 

wiliamrikard(gparkerpoe.com 

ericwelsh(gparkerooe.com 

John F. Graybeal 

PARKR POE ADAMS & BERNSTEIN, LLP 

150 Fayettevile Street 

Raleigh, NC 27602 

Telephone: (919) 835-4599 

Facsimile: (919) 828-0564 

i ohngraybeal(gparkerpoe.com 

Attorneys for Respondent 

2 

PPAB 1520233vl 
UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

In the Matter of ) 

) Docket No. 9327

)

Polypore International, Inc. )
 

a corporation ) PUBLIC DOCUMENT
 

)
 

STATEMENT PURSUANT TO 16 C.F.R. § 3.22(0 

I, Eric D. Welsh, Esq., on behalf of Parker Poe Adams & Bernstein LLP ("Parker Poe") 

as counsel for Polypore International, Inc. ("Polypore"), hereby represent that Parker Poe has 

conferred with counsel for The Moore Company in an effort in good faith to resolve by 

agreement the issues raised by The Moore Company's Motion to Limit Subpoena Duces Tecum 

and for Cost Reimbursement and Polypore's Cross-Motion to Compel The Moore Company to 

Produce Documents Requested by Subpoena Duces Tecum and have been unable to reach such 

an agreement. 

Parker Poe and counsel for The Moore Company discussed these issues in 

correspondence on November 26,2008, December 10,2008, December 12,2008, December 15, 

2008 and December 16, 2008. Additionally, Parker Poe met with counsel for The Moore 

Company by conference call, including on November 17, 2008 and November 25, 2008, to 

fuher discuss these issues. During this call, I was present for Parker Poe and Michael 1.
 

Connolly, Esq. and/or Betsy Myers, Esq. were present for The Moore Company. 

As a result of these discussions it was concluded that Polypore and The Moore Company 

were at an impasse with respect to the issues raised in their respective motions. 

PPAB 1520233vl 
Dated: January 8, 2009 Respectfully Submitted,
 

u ~ ?/~ J-


Eric D. Welsh 

PARKR 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(gparkerpoe.com
 

PPAB 1520233vl 
CERTIFICATE OF SERVICE 

I hereby certify that on Januar 8, 2009, I caused to be fied via hand delivery and 

electronic mail delivery an original and two copies of 
 the foregoing Respondent's Cross-Motion 

to Compel The Moore Company To Produce Documents Requested by Subpoena Duces 

Tecum, and that the electronic copy is a true and correct copy of the paper original and that a 

paper copy with an original signature is being filed with: 

Donald S. Clark, Secretary 

Office of the Secretary 

Federal Trade Commission 

600 Pennsylvania Avenue, NW, Rm. H-135 

Washington, DC 20580 

secretary(gftc. gov 

I hereby certify that on January 8, 2009, I caused to be served one copy via electronic 

mail delivery and two copies via overnight mail delivery of the foregoing Respondent's CrossMotion to Compel The Moore Company To Produce Documents Requested by Subpoena 

Duces Tecum upon: 

The Honorable D. Michael Chappell 

Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, DC 20580 

oali (gftc. gov 

I hereby certify that on January 8, 2009, I caused to be served via first-class mail delivery 

and electronic mail delivery a copy of the foregoing Respondent's Cross-Motion to Compel The 

Moore Company To Produce Documents Requested by Subpoena Duces Tecum upon: 

J. Robert Robertson, Esq. Steven Dah, Esq. 

Federal Trade Commission Federal Trade Commission 

600 Pennsylvania Avenue, NW 600 Pennsylvania Avenue, NW 

Washington, DC 20580 Washington, DC 20580 

rrobertson(gftc.gov sdahm(gftc.gov 

Michael J. Connolly
 

Laura B. Angelini
 

Hinckley, Allen, & Snyder LLP
 

28 State Street
 

Boston, Massachusetts 02109- 1 775
 

mconnollv~HASLAW.com
 

lanqelini~HASLAW.com
 

PPAB 1520233vl 
()Ji Adam C. Shearer
 

Parker Poe Adams & Bernstein LLP
 

Three Wachovia Center
 

401 South Tryon Street, Suite 3000
 

Charlotte, NC 28202
 

Telephone: (704) 335-9050
 

Facsimile: (704) 334-4706
 

PPAB 1520233vl