[Stolen Cell Phone] Roxie Takes Her Brand New Cell Phone

[Stolen Cell Phone] Roxie takes her brand new cell phone to the gym after work. She places it in a locker in the woman's locker room, which is not secured. There are signs conspicuously posted on both the door to the locker room and the wall above the lockers which say "Rent a lock at the front desk for $1.00. This gym is not responsible for items stolen from unlocked lockers." Roxie reads the sign, but not wanting to delay her workout, she decides to hide the phone under her clothes in the locker. She closes the locker, but leaves it unlocked as leaves the locker room to work out. An hour later she completes her workout and returns to the locker, only to find that her new phone has been stolen from the unlocked locker. She sues the gym for the value of the phone.
-Assuming that the gym is not liable, what would be the reason why?

A) Because the gym is a public facility in which there is a lessened expectation of liability than in private or exclusive facilities.
B) Because the phone was stolen by a third party, and the act was therefore out of the gym's ability to control.
C) Because an express bailment must be in writing and signed by both parties, and no such agreement was in place in this scenario.
D) Because the gym limited their liability by posting conspicuous signs describing the limits of their liability.
E) Because an implied bailment requires knowledge of the existence of the bailed property by both parties, and Roxie hid the phone in her clothes.