Yellow, 406 F.Supp.2d at 1219. In reaching this conclusion, the court undertook an extensive analysis of the case law and legislative history surrounding the requirement that the defendant attach process to a notice of removal. Id. at 1215-19. First, the court noted that a majority of courts have held that “ ‘mere modal or procedural defects [in removal] are not jurisdictional’ and that under § 1446(b) missing state court papers may be supplied later.” Id. at 1215 (quoting Covington, 251 F.2d at 933). Because process may be supplied later, failure to attach it is a curable defect rather than a substantive error that requires remand. Id. at 1216. The court also recognized that a failure to attach process — although never addressed by the Tenth Circuit— was 29-30 (D.Mass.1958) (<HOLDING>). While recognizing that some districts have
holding that the information supporting removal in a copy of an amended pleading  must be unequivocally clear and certain to start the time limit running for a notice of removal internal quotation omitted holding that notice of removal was defective on its face because it failed to contain a copy of the process as required by the removal statute holding that any defect in removal procedure must be cured within the 30day removal period or it is fatal to the removal and defendants failure to attach exhibits to the notice of removal within that time required remand holding that the defendants filing of a notice of removal before being served by plaintiffs did not render removal defective holding that the defendants motion to amend their notice of removal was proper due to plaintiffs waived objections to the sufficiency of the notice of removal by failing to seek remand within thirty days of removal