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3. Howe writes a check to Sally in the amount of $100.00. Sally endorses the back of the check and places it in her purse. Later that evening, Tom the thief takes the check from Sally's purse. The next morning Tom the thief cashes the check at the bank on which it is drawn. Sally contacts Howe, who contacts the bank and demands that the money be redeposited in his account. The bank refuses to do so. Who wins? a. Howe wins because the check is stolen, and the bank has no right to cash it. b. Howe wins because checks are always order paper and require the signature of the person who is cashing it with the drawee bank. c. The bank wins because once Howe writes the check and releases it, the bank is obliged to pay it regardless of the intervening circumstances. d. The bank wins because Sally's blank endorsement changed the check from order paper to bearer paper, and made it properly payable to whoever was in possession of the check