Under an antenuptial agreement executed in Quebec, P made D the beneficiary of a $125,000 trust fund. Later, in consideration for renouncing her interest in this trust fund, D was made the beneficiary of a $1,000,000 trust, under an instrument executed in Quebec at the settlor's domicil, but with a New York trustee, the trust to be administered in New York where a substantial portion of the res was located at the time of settlement. Under the local law of Quebec such modification of the antenuptial agreement was invalid; under the local law of New York it was valid. When P sued in New York to revoke the trust, it was held that the local New York law was applicable. Hutchison v. Ross, (N. Y. 1933) 187 N. E. 65.