In Greenleaf v. Lachman, 216 AD2d 65 (1st Dept 1995) the issue was whether the defendant stepson could rely on an exception to the rule against admitting parol evidence to vary the terms of a writing, the promissory note that the plaintiff stepfather had induced him to sign with the explanation that it was only to avoid having to pay gift taxes on it. Given the stepfather's intent to avoid paying gift taxes, which was against public policy, the Greenleaf Court ruled for the stepson. I thus held that the failure to name all of the parties to the note, along with a cause of action for violating public policy, constituted valid defenses. (Id. at 7).