Oscar, owner of Greenacre, conveyed Greenacre by quitclaim deed as a gift to Ann, who did not then record her deed. Later, Oscar conveyed Greenacre by warranty deed to Belle, who paid valuable consideration, knew nothing of Ann's claim, and promptly and properly recorded. Next, Ann recorded her deed. Then Belle conveyed Greenacre by quitclaim deed to her son Cal as a gift. When the possible conflict with Ann was discovered, Cal recorded his deed. Greenacre at all relevant times has been vacant unoccupied land. The recording act of the jurisdiction provides: "No unrecorded conveyance or mortgage of real property shall be good against subsequent purchasers for value without notice, who shall first record." No other statute is applicable. Cal has sued Ann to establish who owns Greenacre. The court will hold for 
Cal, because Ann was a donee.  Cal, because Belle's purchase cut off Ann's rights.  Ann, because she recorded before Cal.  Ann, because Cal was a subsequent donee. 