A negotiable instrument must be issued to be legally effective, and it must be delivered before it is deemed to be issued. In which of the following has delivery occurred?

1) The drawer of a check placed the check in the out basket of her desk. She died of a heart attack before the check could be given to the payee.

2) The maker of a note gave it to an agent of the payee, but the agent never delivered it to the payee.

3) The payee of a note found the note on the maker's desk and took it without permission.

4) The drawer of a check lost it before mailing it. The finder gave it to the named payee.