ld "apply the local law of that state which has the greatest interest in or the most significant relationship to the transaction and the parties." See Thar Fund. Inc. !Ins. Co. of N. Am., 580 Kid 1158. 1162 (2d i, 1978). cat denied, 440 U.S. 912, 99 S.Ct. 1226. 59 L.Ed.2d 461 (1979). In the present action,