The caller's voice sounded the same as the other calls. Gilbert later told Perrault that she had made a phone call from the Tasty Top booth to check her answering machine and that she had seen a State Trooper at the Tasty Top. James Perrault During the fall she began having an affair with him. The voice on all three calls sounded the same to Perrault. Flashcards. Janet Knott/The Boston Globe via Getty ImagesJulia Hudon, 67, and Christine Duquette, 43, mourning the loss of their son and brother, Henry Hudon, murdered by Kristen Gilbert. Nothing is going to stop these people," she said. stood trial for calling in a bomb threat to the Northampton VAMC to retaliate against coworkers and former boyfriend James Perrault (who also worked at the hospital) for their . Nancy and son Jeff Cutting, the family of Kenneth Cutting, when Gilbert was found guilty of murderingthe former soldier. At the same time, the VAMC noted that there was an increase in the number of fatal heart attacks. But no one could believe that the smart, controlled, and pretty, young nurse could be capable of murder. By fall, Gilbert was having an extramarital affair with Perrault. I, 8, cl. In its opening statements, The New York Times reported at the time, the prosecution said Gilbert killed her victims in order to show off her nursing skills and impress James Perrault, who would be called in any emergency situation. Friends and former beaus, however, said she was also a habitual liar, thief and manipulative person. As reported by Medical Bag, Gilbert was accused of killing or attempting to kill patients at the Veterans Affairs Medical Center in Northampton, Massachusetts where she worked. at 19. She asked Perrault to talk to her and not to go to the interview. The victims' families are split on a death sentence. Gilbert was upset by the investigation and made her feelings known. She was acquitted of that charge in the case of another veteran, Francis Marier. Shortly before the 6:37 p.m. pay-booth phone call, Massachusetts State Trooper Kevin Murphy, who was on surveillance, saw Gilbert arrive in her car at the Tasty Top, an ice cream stand, and use the pay telephone booth outside of it. Gilbert took the position at trial that evidence of the other investigation should not have been admitted at all. Gilbert's parents, Richard and Claudia Strickland, of Setauket, N.Y., sat behind her in the courtroom. Learn. Kristen Gilbert was born on the 13th of November 1967 in Fall River, Massachusetts. One of her co-workers was a Persian Gulf War veteran named James Perrault who was a police officer at the hospital. He also noticed that the calls seemed directed at him personally. [14] After a fake suicide attempt, she was ordered into psychiatric treatment by Bridgewater State College officials. Goodbye. Glenn Gilbert described the voice as an altered voice, an almost haunting voice.. By 1995, casual flirting between Kristen and Perrault had blossomed into a full-on extramarital affair. Per the Boston Globe, she later called Perrault from the psych ward telling him, "You know I did it. Co-workers were taken aback by the couples unprofessional public displays of affection. at 559, 115 S.Ct. stood trial for calling in a bomb threat to the Leeds VAMC to retaliate against co-workers and her former boyfriend James Perrault who worked at the hospital for . Kristen Gilbert was known to be a dutiful and dedicated nurse at VA Medical Center in Northampton, Massachusetts. Kristen Gilbert, who had two children and was divorced from Glenn Gilbert, was convicted on March 14, 2001 in federal court. She lived in the suburbs of Massachutes, was a recent newly-wed and . I did it. Kristen H. Gilbert Information researched and summarized by Elizabeth Daly, Kanika Davis, Sarah DeHart, & Michael Palmadesso . constitutes the sort of other-act evidence that falls within the scope of Rule 404(b). Richard was an electronics executive, while Claudia was a homemaker and part-time teacher. Prosecutors said she also once climbed atop a patient and straddled him, apparently so Perrault could see her garter belt. He survived the incident, though not without great reservations about his wife. She was convicted on three counts of first-degree murder, one count of second-degree murder, and two counts of attempted murder. Gilbert forced an untrained colleague to use cardiac defibrillation paddles on a patient during a medical emergency on November 17, 1995, by refusing to use the equipment herself. This case is not precisely on point but it illustrates that affecting interstate commerce is not the sole test to use in determining whether there is interstate commerce jurisdiction. A later study released by the prosecution in her trial would find the statistical probability of that happening was1 in 100 million. I'm a true crime writer and podcast producer. The prosecutor in her case, Assistant US Attorney William M. Welch II, asserted that Gilbert used these emergency situations to gain the attention of then-boyfriend Perrault,[18] a VA police officerhospital rules required that hospital police be present at any medical emergency. In fact, she had met him there on several prior occasions, without notice beforehand. The procedural history of the voice identification is important. She was dutiful and dedicated, just like any good nurse would be, or at least that's what her coworkers believed. [22], On March 26, 2001, the jury recommended a sentence of life imprisonment. Female. The fact that she was included for a time in that separate investigation is simply not evidence against her in this case in any way. Prior to the bomb threat, Gilbert and some others were the subject of an investigation by the VAMC police and other police agencies. The Court did not consider the affecting commerce question. She was also convicted of assault with intent to kill Angelo Vella and Thomas Callahan. For a time that separate investigation included within its scope, among other people and things, the defendant here Kristen Gilbert. Learn. Gilbert was also jokingly known as the "Angel of Death" among. But unbeknownst to them, she had a history of lying and manipulating. Glenn sobrevivi al incidente y Kristen lo dej a l y a los nios poco despus, por James Perrault. I believe also that the probative value of the evidence outweighs any unfair prejudice that will be done to the defendant as a result of my letting this in, particularly in the context of the limiting instruction that I will give. On arriving at Springfield, Perrault used a parking garage that he and Gilbert had used on prior occasions. September 14, 2019 CRJ 305 - Fall 2019 Essay 2 Explain the general facts of the case and the holding while defining guilty by reason of insanity, the M'Naghten Rule and the Irresistible Impulse Test. During the next several days Perrault's car was stained by egg yolks from eggs that had been thrown at it, the windshield was spray-painted, scratches were made on the exterior by keys, and the front license plate was damaged. Create a free profile to get unlimited access to exclusive videos, breaking news, sweepstakes, and more! YouTubeUnassuming serial killer Kristen Gilbert. It was then that she began an extramarital affair with James Perrault. The telephone calls on exhibit 13 were tape-recorded messages; the messages had been pre-recorded on the Talkboy, and then played back at a slower speed. 11-01-1995 27 Perrault rented an apartment in Easthampton, to be closer to Gilbert 11-95 27 Gilbert moved out of her house . The Act neither regulates a commercial activity nor contains a requirement that the possession be connected in any way to interstate commerce. No . Flashcards. She went on to get her nursing degree at Greenfield Community College in 1988 when she married Glenn Gilbert and began working at Northamptons Veteran Affairs Medical Center. Female. James Perrault Assistant Vice President, Client Operations at State Street Franklin, Massachusetts, United States 307 connections You wanted to know? One syringe was filled with a clear liquid and Kristen told her husband it was just a saline solution. And even if we were skeptical about the prosecutor's assertion, we would be bound by the district court's decision to admit the evidence. Gilbert argues that the admission was erroneous for three reasons: (1) ambush, abuse of discretion, and deprivation of a fair trial; (2) the voice identifications were unduly suggestive, inherently unreliable, and constituted an abuse of discretion; (3) the trial court's refusal to give an adverse inference instruction constituted reversible abuse of discretion. These activities assuredly brought the gold mine within 1962(a)'s alternative criterion of any enterprise engaged in interstate or foreign commerce. Id. She allegedly tried to poison her husband while he was receiving care at Cooley Dickinson, a local civilian hospital. [16], Gilbert left the hospital in 1996 amid a hospital investigation into the many suspicious patient deaths that occurred during her shifts. Her work at the Northampton VA hospital was rewarding, challenging, and exciting. Perrault also testified that Gilbert used to grind her hips into him during medical emergencies. Mr. Strickland covered his face with his hand as the verdict was announced. Oxygen Insider is your all-access pass to never-before-seen content, free digital evidence kits, and much more! Appellant's Br. Mr. Koenig created a speed-corrected tape of exhibit 13, which became exhibit 44. She admitted to Perrault that she watched from across the street as the building which the caller said contained three explosive devices was evacuated. Moreover, there was sufficient evidence for the jury to convict without the voice identification of the September 30 Talkboy telephone calls. In 1988, she married boyfriend Glenn Gilbert, with whom she would have two sons, and became a registered nurse. Just wait and see what I have planned for you. Perrault recognized the voice as being the same as the one in the prior phone calls. We first turn to the interstate commerce-jurisdiction issue. On Monday, January 12, the prosecutor proffered Koenig as a witness. 41:969 FEDERAL DEATH PENALTY murder trial,7 with jurors deadlocked and, thus, the option of im- You may hear references to that investigation, and I am therefore permitting you to know of the fact of that separate investigation. Search Tags. A warrant-authorized search was made of Gilbert's apartment during the evening of October 1. The investigators never told Gilbert that they were looking for a child's toy that could change a person's voice. On the surface, she Kristen seemed to live a happy life. She year-old rounded up her high school education at Groton-Dunstable Regional High School at the age of 16 and thereafter attended two other colleges before proceeding to Greenfield Community College. During the trial, Kristen admitted that she carried out all those killings just to show off to Perrault. Apart from parents, Kristen Gilbert also had a younger sister with whom she grew up. On January 7, after the trial started, the government sought to have Gilbert's ex-husband Glenn Gilbert, identify defendant's voice by playing exhibit 13 on a voice transmitter with a variable speed adjustment. There was testimony by two witnesses, a long time friend of Gilbert and Gilbert's ex-husband, that the voice on exhibit 44 was that of defendant. In the summer of 1995 Gilbert and Perrault became friendly. A judge later sentenced Gilbert to four consecutive life sentences with no chance for parole,according to The Associated Press. First, Congress may regulate the use of the channels of interstate commerce Second, Congress is empowered to regulate and protect the instrumentalities of interstate commerce, or persons or things in interstate commerce, even though the threat comes only from intrastate activities Finally, Congress' commerce authority includes the power to regulate those activities having a substantial relation to interstate commerce , i.e., those activities that substantially affect interstate commerce. She induced cardi They almost all occurred in Ward C, the area where Gilbert worked. The court sustained Gilbert's objection, subject to a change of ruling if the government obtained an expert witness. The staff is talking to the patients about it, Gilbert went unsuspected. The night security guard (James G. Perrault) What was Kristen injecting into her patients? Prosecutors said Gilbert threatened the life of at least one person verbally and physically in July 1996. Investigators discovered that Gilbert would inject her victims with epinephrine, sending them into cardiac arrest. "She was e-mailing her lover while my son was there dying," Julia Hudon said. The supposed wrongdoing involved something else entirely. You should not, as a matter of law and as a matter of fundamental fairness, assume in any way that Ms. Gilbert is or might be guilty of phoning in a bomb threat simply because she happened to fall within the scope of a separate investigation involving something entirely different. On the evening of September 27, Perrault received two anonymous telephone calls while on duty at the security desk. Convicted on four counts of murder, its possible the victims Gilbert left in her wake numbered even more. 55-year-old Kristen Gilbert, a former nurse, was accused of killing several patients at a hospital while she was working there. On one of those days, she called up her boyfriend, James Perrault, and confessed to the killings. Plante contacted Perrault at the VAMC security desk, who confirmed that he had just received a call in which there was traffic noise and heavy breathing noise. Consider this evidence only in this light. I have also instructed counsel not to refer to the specifics of that investigation. The government was dealt an early blow in the trial when prosecutors were forced to drop a key piece of evidence. She had a history of faking suicide attempts to manipulate people. On the same evening, September 30, other departments at the VAMC, i.e., Admissions and the Nurses' Station on Ward C, also received unidentified phone calls. First Name: Kristen. In 2001, Kristen Gilbert was found guilty on three counts of first degree murder, one count of second degree murder, and two counts of attempted murder by a federal jury. In the case of Cutting's death,they claimed she killed him simply to leave her shift early and meet him for a dinner date. Gilbert's second contention is that the voice identifications were unduly suggestive and their admission an abuse of discretion because the witnesses already knew Gilbert's voice but were not given comparisons of tape recordings of other voices. The prosecutor had given her, as soon as it was available, a statement of the testimony of its expert that would be proffered at trial. Around the same time that she quit her job, she was in and out of the psychiatric department for treatment. Learn more about FindLaws newsletters, including our terms of use and privacy policy. Before her trial, prosecutors claimed that Glenn Gilbert told one witness that his wife was trying to have him out of the house by Thanksgiving.. But later, Gilbert told him she was only trying to make him angry, Perrault said. After being assigned to the night shift, Gilbert began an extramarital affair with a hospital security guard, James G. Perrault, an Army veteran of the Persian Gulf War. One of Gilbert's friends, Ms. Abderhalden, who had known and worked with Gilbert for over five years and had talked to Gilbert daily in the fall of 1996, identified the voice on exhibit 44 as Gilbert's voice, as did Glenn Gilbert her former husband. She would then respond to the coded emergency, often resuscitating the patients herself. The 5:41 p.m. and 5:44 p.m. calls were traced to telephone pay stations at a Citgo gas station and the Daily Hampshire Gazette. On September 27th, Gilbert purchased a Talkboy Jr. which like the Talkgirl Jr. could make a woman's voice sound like that of a man. Perrault believed that the voice on these calls was the same as the one that had made the bomb threat calls. The first paragraph of Lopez summarizes the case: In the Gun-Free School Zones Act of 1990, Congress made it a federal offense for any individual knowingly to possess a firearm at a place that the individual knows, or has reasonable cause to believe, is a school zone. 18 U.S.C. As the prosecutor fiddled with the tape recorder that held exhibit 13, he became aware that when the play back speed of the recorder was increased that Gilbert's natural voice was heard. After learning about Kristen Gilbert, get a look at other people leading violent double lives with fellow angel of mercy, Genene Jonesand Karen Boes, who may have falsely confessed to her daughters murder. The jury could well have found that her reaction to the investigation as shown by what she said and did was the motive for the bomb threat. Kristen's college roommate was led show more content The prosecutor accused Kristen Gilbert of murdering her patients for the fun and to impress James Perrault. The government promptly contacted an expert, Bruce Koenig, who was in the business of analyzing audio and video tapes. Kristen Gilbert may have feared that the illicit nature of her affair wouldnt be enough to keep their hearts beating for one another, and began to manufacture scenarios, possibly to impress Perrault. One of the deaths was of 66-year old Stanley Jagodowski. Created by. While the police were executing the search warrant, Gilbert went over to her neighbor's (O'Donnell) apartment. [9][14] She graduated from the latter with a nursing diploma, becoming a registered nurse in 1988. In 1989, Gilbert joined the staff of the Veterans Affairs Medical Center in Northampton. To divert the attention of the investigators, Gilbert made a hoax call at the hospital about a bomb being planted there. Jump into read her life Facts, Wikipedia and biographies Details . Kristen was sentenced to life imprisonment on three counts of first-degree murder, one count of second-degree murder, and two counts of attempted murder. We do not doubt that Gilbert was surprised by the positive voice identification testimony. Sign up forOxygen Insiderfor all the best true crime content. The judgment of the district court is affirmed. Kristen Heather Gilbert (born Kristen Heather Strickland, November 13, 1967) is a former nurse and an American serial killer who was convicted of four murders and two attempted murders of patients admitted to the Veterans Affairs Medical Center (VAMC) in Northampton, Massachusetts. Perrault received three phone calls during the evening of September 30. Her killings escalated when she met James Perrault, a policeman working at the VA Center, while on the night shift. On October 1, 1996, Perrault met with investigators and it was agreed that he would call Gilbert when he started his shift on the security desk at 5:00 p.m. Surveillance of a number of pay telephone booths in the vicinity of Gilbert's apartment was arranged for that evening. Agent Plante also found a Daily Hampshire Gazette, dated September 27, 1996, on Gilbert's bed that contained an article about the bomb threat. Kristen Gilbert, 33, could have been sentenced to lethal injection and would have become the only woman on federal death row. Glenn Gilbert began to get sick. 3. KRISTEN GILBERT, DEFENDANT, APPELLEE. The cashier who sold the toy to Gilbert remembered that Gilbert wanted to be sure that the batteries worked with it and that Gilbert told her she wanted the toy for her nephews. Death rates during Kristen's shifts began tripling. This was a judgment call by the district court under an abuse of discretion standard, and we do not think that the discretion was abused. In 2001, American serial killer and former nurse Kristen Gilbert was convicted of killing four of her patients. The friendship blossomed into a full-blown affair in September and October of 1995. Atrapada. Kristen Gilbert was known to be a dutiful and dedicated nurse at VA Medical Center in Northampton, Massachusetts. Kristen Gilbert went on trial in November 2000 for the deaths of Cutting, Skwira and two others, as well as three counts of attempted murder. John Blanding/The Boston Globe via Getty Images. Trooper Murphy radioed to Special Agent Plante (a member of the surveillance team). "Every single one of these people had a coronary disease, were at risk for a coronary disease or at risk for sudden cardiac death," defense attorney David Hoose said in closing arguments. The batteries could be used to activate the Talkgirl Jr. The toy is a hand-held voice changer that records a statement which can be played back at a higher or lower speed than the original recording. She was convicted on three counts of first-degree murder, one count of second-degree murder, and two counts of attempted murder. Gilbert was born Kristen Heather Strickland in Fall River, Massachusetts, on November 13, 1967, the elder of Richard and Claudia Strickland's two daughters. , while a student at Bridgewater State College, she was ordered to receive psychiatric treatment after faking a suicide attempt and telling her ex-boyfriend she had eaten glass. For these reasons, Gilbert says that the trial judge should have excluded the identifications in this case. Maybe, like Jane Toppan, she was aroused by watching life slip away as she administered epinephrine to healthy hearts essentially adrenaline exciting the hearts to pump out of control. [21] Though Massachusetts does not have capital punishment, her crimes were committed on federal property and thus subject to the death penalty. The testimony of the recipients was that the voice sounded as being electronically altered or was a mechanical sounding voice. He was of the opinion that the caller was Gilbert. "My heart just went," said Julia Hudon, the 67-year-old mother of murdered veteran Henry Hudon, grasping her chest as she recalled hearing the guilty verdict. UNITED STATES, Appellee, v. Kristen GILBERT, Defendant, Appellant. The investigation became an official criminal investigation in a few months. In late July, 1996, Gilbert told a friend of hers that if Perrault dumped her, she probably would start stalking him. Perrault tried again in late August of 1996 to break his relationship with Gilbert. She was well-liked by her co-workers, who remember her organizing the yearly Secret Santa for staff and gift drives for disadvantaged families. He worked from 3 p.m. until 11 p.m. and the two often went to have drinks with other workers at the end of their shifts. The increase in deaths and shortage of epinephrine at the same time was alarming, so three nurses decided to report it to the authorities. Kristen Heather Gilbert ( ne Strickland; Fall River, 13 de novembro de 1967) uma assassina em srie e ex- enfermeira americana que foi condenada por quatro assassinatos e duas tentativas de assassinato de pacientes internados no Veterans Affairs Medical Center (VAMC) em Northampton, Massachusetts. The messages received were as follows: All of the phone calls had the same ring pattern, indicating that they were made from outside the VAMC. Koenig increased the playback speed for exhibit 13, the tape containing the September 30th phone calls, by 31.1%. The defense's argument was based on Kristen 's patients had died of natural causes, Kristen was doing her job by doing the best she could and that everybody must die at some . Maybe she just basked in the attention of swooping in and restoring life. We do not think, however, that she was ambushed by it, if we define ambush as the government deliberately laying a trap for her to walk into. At the center of Gilbert's attention, when most of the deaths and codes occurred, was a hospital security officer named James Perrault, described in court documents as her "erstwhile paramour." A pen register was installed on Gilbert's phone on September 26, after the bomb threat. Check out never-before-seen content, free digital evidence kits, and much more! She induced cardiac arrest in patients by injecting their intravenous therapy bags with massive doses of epinephrine, an untraceable heart stimulant. In addition to the four murders, Gilbert was found guilty of trying to kill two other patients who did not die. Kristen Gilbert can be classified as an organized murderer.She killed for the thrill and power involved. Because, however, the admission of the voice identification was not error, we need not decide whether it would have been harmless error. At her 2000 trial, prosecutors alleged that Gilbert killed her patients to show off to Perrault. Kristen Gilbert The hospital assigned Kristen to the night shift. We dont talk enough about how cute Kristen Gilbert was 2001 Angel of Death Kristen Gilbert is convicted. Section 1962(a) prohibits the acquisition of any interest in, or the establishment or operation of, any enterprise which is engaged in, or the activities of which affect, interstate or foreign commerce.. Though many were old or sick, several did not have heart problems but somehow died of cardiac arrest. The case was brought under the Racketeer Influenced and Corrupt Practices Act (RICO) on the basis that defendant had invested proceeds obtained from unlawful acts proscribed by RICO, in the purchase and operation of a gold mine. . at 558, 115 S.Ct. Match. We do not think that the investigation evidence is barred by either Rule 403 or Rule 404(b). And Gilbert was accorded an extensive voir dire of the government's expert before he testified before the jury. . ix months after Kristen Gilbert began work on the VA Medical Center's evening shift, James G. Perrault, an Army veteran of the Persian Gulf War who had been working as a department store. Oxygen's Snapped is all set to detail the chilling story of serial killer Kristen Gilbert. The court was of the opinion that allowing the government to vary the speed of the play back to obtain Gilbert's natural voice would be unreliable and too haphazard. The pen register showed that, between September 26 and October 1, 1996, about one half of Gilbert's phone calls to Perrault used a method (called the *67 function) which prevented Perrault from tracing her calls from his own telephone. He contacted NYNEX which traced seven of the calls to Gilbert's telephone number. Trooper Murphy seized from the trash three empty battery packages for Energizer batteries, two batteries stamped LI54 on the back, and a Thrifty Drug Store receipt showing the purchase of the Energizer batteries. Both the defense and the prosecution are under a gag order. They all had been under her care at the Veterans Affairs Medical Center at the time of their deaths. Born on May 29, 1991 (age 31) Rule 401 defines relevant evidence. That killer, prosecutors say, was Kristen Gilbert, 33, a former nurse, who is on trial in federal court here, accused of killing four patients and trying to kill three others by injecting them. In addition, both witnesses had listened to exhibit 44 prior to testifying and identified the voice as that of Gilbert. Perrault answered a security desk phone call at 5:11 p.m. A recorded message from an unidentified caller stated: This message is for all Persian Gulf veterans who were exposed to chemical weapons. Perrault was a Persian Gulf War veteran and Gilbert knew it. I killed those guys." As the district court pointed out, it could be described as part of the proof that Gilbert was the one who made the telephone bomb threat. On the weekend prior to trial, the prosecutor was fooling around with exhibit 13 on a play back tape recorder. Moreover, Gilbert had been furnished a copy of exhibit 13 over a year prior to trial. Military veterans are responsible for safeguarding our country, and as such, they are granted comprehensive health care by the Department of Veteran Affairs. In the summer of . There was no voice communication, only heavy breathing or hang-ups. We hold that the other investigation evidence was properly admitted. James Perrault was a VAMC police officer who worked the 3:00 p.m. to 11:00 p.m. shift at the medical center. As a result, Film Daily reports that Gilbert quit her job. Snapped Notorious: Prescription for Death, Kenneth Cutting, 41, and Edward Skwira, 69, as well as three counts of attempted murder, after deliberating for two days according to CBS News. Family members of the victims let out gasps of relief. One of her co-workers was a Persian Gulf War veteran named James Perrault who was a police officer at the hospital. The calls were made by someone who knew Perrault's work schedule, which Gilbert did. An undated yearbook photo of Gilbert, the killer VA nurse. However, a series of unusual deaths started to take place at the hospital where she was working. Her superiors at the hospital were pleased with her capability and her work. The episode, titled Notorious: Kristen Gilbert, will air on Sunday, January 15 at 9 pm ET. Evidence of other crimes, wrongs or acts is not admissible to prove the character of a person in order to show action in conformity therewith. She also allegedly liked the "thrill" of medical emergencies. She was transferred from a prison for women in Framingham, Massachusetts to FMC Carswell in Fort Worth, Texas, where she has remained ever since. The Witnesses. On the day of the interview, Gilbert blocked Perrault's car with her car as he attempted to drive out of his driveway. Kristen Gilbert Biography. The court then acknowledged that it might be wrong about Rule 404(b)'s applicability and stated that it was going to make a finding under Rule 404(b) to cover the situation:. Test. By then, Gilbert had quit her job and was institutionalized for a suicide attempt. Klub; . "I'd rather see her just sit in jail," said Nancy Cutting, the widow of veteran Kenneth Cutting. The pertinent part of Rule 404(b) states: (b)Other crimes, wrongs, or acts. Murders A-Z is a collection of true crime stories that take an in-depth look at both little-known and famous murders throughout history.
Ohio Permit Test In Russian,
Snoop Dogg Jacket In Corona Commercial,
Don Cornelius And Gladys Knight Married,
Severn River Bridge Accident Today,
Articles K