Holding that where in the state court depositions were taken, discovery requests and thousands of documents were exchanged, the state court has placed the case on its complex administrative track, and defendants have moved for summary judgment, and the federal action were still in the initial pleading stage, the "progress" factor weighed strongly in favor of deferring to the state court
Holding that the district court erred in exercising jurisdiction over a shareholder's complaint seeking the liquidation of a Pennsylvania corporation, because state statutes established a mechanism for the shareholder to achieve the same results
In Harkin v. Brundage, 276 U.S. 36, 48 S.Ct. 268, 72 L.Ed. 457, the court held that jurisdiction of the Federal court [(D.C.) 13 F.2d 617] was invoked through the practice of fraud by the moving litigant and therefore must be surrendered.