Maya stole a check from Orhan payable to the order of Orhan. Maya forged Orhan's signature and presented the check for payment at Winston Bank, which honored the check. If Orhan sues Winston Bank for the amount of the check, under what theory, can Orhan recover the funds from the bank?

Multiple Choice

• Conversion

• Fraud

• Unfair and deceptive practices

• Fictitious payee rule