involved. Therefore, this factor is not relevant to the Court’s instant abstention analysis. b. Inconvenience of the federal forum In assessing the appropriateness of dismissal where concurrent jurisdiction exists, “a federal court may also consider such factors as inconvenience of the federal forum.” Colorado River, 424 U.S. at 818, 96 S.Ct. 1236. Plaintiff argues that this factor weighs against abstention because it i Snohomish County Superior Court of approximately 28 miles is too minimal to weigh against abstention. c. The desirability of avoiding piecemeal litigation The avoidance of piecemeal litigation can be an important factor against concurrent federal proceedings. Colorado River, 424 U.S. at 819, 96 S.Ct. 1236; see also Holland v. Hay, 840 F.Supp. 1091, 1101 (E.D.Va.1994) (<HOLDING>). Piecemeal litigation arises “when different
recognizing that the colorado river doctrine is necessary to ensure judicial economy and deter abusive reactive litigation holding that the most important factor in the preservation hierarchy is whether the relevant issue was raised in the trial court and the least important factor is whether the appellant alerted the trial court to the specific argument raised on appeal holding that the district court could not stay erisa and 1934 act claims under colorado river recognizing that the third factor permanence is the most important recognizing that the supreme court has referred to the policy of avoiding piecemeal litigation as by far the most important colorado river factor