important state interests); see also 17A Moore’s Federal Practice § 122.05[2][d] (3d ed.2012) (describing the extension of Younger). We have come to view O’Shea as standing for the more general proposition that “[w]e should be very reluctant to grant relief that would entail heavy federal interference in such sensitive state activities as administration of the judicial system.” L.A. Cnty. Bar Ass’n v. Eu, 979 F.2d 697, 703 (9th Cir.1992). O’Shea compels abstention where the plaintiff seeks an “ongoing federal audit” of the state judiciary, whether in criminal proceedings or in other respects. E.T. v. Cantil-Sakauye, 682 F.3d 1121, 1124 (9th Cir.2011) (per curiam), cert. denied, — U.S. -, 133 S.Ct. 476, 184 L.Ed.2d 297 (2012); see also Kaufman v. Kaye, 466 F.3d 83, 86 (2d Cir.2006) (<HOLDING>). In Los Angeles County Bar Ass’n, the
holding jurisdiction over nonresident defendant existed where note was payable in new york contained new york choice of law clause and proceeds were used to finance new york limited partnership holding that abstention was required where the relief sought would be overly intrusive in the administration of the new york court system holding that neither the new york location of the terrorist attack giving rise to the policyholders claim nor the new yorkbased claims adjustor rendered new york the locus of operative facts because new york was not the site of the contracts execution holding that contract signed in new york by promisor from florida and partially performed in florida was governed by new york law because it was executed in new york holding that exhaustion is required even where the relief sought is not available in the administrative process