Sanders borrowed $5,000 from Waskow, giving Waskow a promissory note that read, “One year from date, I promise to pay to the order of James Waskow $5,000, without interest (signed) Mary Sanders.” Six months later, Waskow died. The unendorsed note was in the possession of Waskow’s landlord, who claimed that Waskow had given him the note in payment of back rent. Was the landlord a holder of the note? Why or why not? See also Smathers v. Smathers, 239 S.E.2d 637 (NC).