Michael Jordan needs some quick cash, so he hits upon a scheme. He lies to Scottie Pippen and says he is collecting money for foreign refugees, so Scottie makes out a note for $500 payable to Michael. Michael indorses the note and delivers it to Dennis Rodman for $500 cash. Rodman, who is unaware of Michael's wrongdoing, gives the check to Phil Jackson as a gift. Scottie discovers Michael's deception and refuses to pay Phil when the note comes due. Will Scottie have to pay Phil? a) Yes, because Phil is treated as a holder in due course under the shelter rule b) No, because Phil did not take the check for value c) Yes, because Phil satisfies all the elements to be a holder in due course d) No, as long as Scottie discovers the fraud within a reasonable amount of time