kristen gilbert james perrault

The government counters that the evidence was properly admissible under Fed. Apart from parents, Kristen Gilbert also had a younger sister with whom she grew up. Create your free profile and get access to exclusive content. James Perrault was a VAMC police officer who worked the 3:00 p.m. to 11:00 p.m. shift at the medical center. The procedural history of the voice identification is important. Kristen Gilbert (Kristen Heather Strickland) was born on 13 November, 1967 in Fall River, Massachusetts, United States, is a Former nurse. During each incident, Kristen's admirable nursing skills shined which impressed 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. However, her reputation started to fall apart after patients under her watch started to die one after the other. Prosecutors, in an attempt to secure a penalty of death, sought to admit evidence of aggravating factors during the penalty phase, including Gilbert's 1998 conviction for the bomb threat; the defense introduced evidence of mitigating factors, including the well-being of Gilbert's two children. The VAMC did not receive any more telephone calls from the anonymous caller after October 1st. After being released, and upon learning that Perrault was cooperating with investigators, she called in a bomb threat at the Northampton VAMC, for which she was later arrested and sentenced to 15 months in jail, according to the Los Angeles Times. A Talkboy Jr. and other incriminating evidence was seized. No. Kristen Heather Gilbert (ne Strickland; born November 13, 1967) is an American serial killer and former nurse who was convicted of four murders and two attempted murders of patients admitted to the Veterans Affairs Medical Center (VAMC) in Northampton, M*achusetts. Friends and former boyfriends recalled her as manipulative. Gilbert purchased a Talkgirl Jr. about three and one half hours before the bomb threat calls to the VAMC on the evening of September 26, 1996. In February 1996, three nurses reported Gilbert, citing the recent death of two patients and the decrease in the supply of epinephrine (via All That's Interesting). , 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. Prosecutors said Gilbert threatened the life of at least one person verbally and physically in July 1996. Shortly after arriving he received a phone call at the bar. Moreover, Gilbert had been furnished a copy of exhibit 13 over a year prior to trial. She was convicted on three counts of first-degree murder, one count of second-degree murder, and two counts of attempted murder. [13], Prosecutors said that Gilbert abandoned a patient undergoing cardiac arrest on November 9, 1995, and then asked another nurse to accompany her on a check of patients. [22], On March 26, 2001, the jury recommended a sentence of life imprisonment. For a time that separate investigation included within its scope, among other people and things, the defendant here Kristen Gilbert. 55-year-old Kristen Gilbert, a former nurse, was accused of killing several patients at a hospital while she was working there. Las cosas comenzaron a desmoronarse para Kristen Gilbert a mediados de los 90 tras las sospechas de las enfermeras sobre la frecuencia de las muertes mientras Kristen estaba de turno. at 558, 115 S.Ct. Atrapada. It is believed that Kristen would put her patients in emergency conditions, because hospital security always came rushing at an emergency, so she could show off her nursing skills and flirt with Perrault. La evidencia tambin comenz a acumularse. As a result of this new relationship, she underwent a complete change of persona; where she was a modest dresser, the typical soccer mom . Gilbert telephoned in a bomb threat to attempt to derail the investigation. No anonymous phone calls were received at the VAMC on either of those days. The supposed wrongdoing involved something else entirely. Gilbert talked about the investigation with Perrault. According to the Boston Globe, she was on duty for half of the 350 deaths that occurred in seven years. On September 26, the following message was received at 3:34 p.m. on the telephone answering machine of Glenn Gilbert, divorced husband of defendant-appellant: I just wanted to say goodbye for the last time. With her marriage crumbling, Film Daily reports that she allegedly tried to poison her husband. Death rates during Kristen's shifts began tripling. 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. Snapped Notorious: Prescription for Death Airs Saturday, May 12th, Snapped Notorious: Prescription for Death, Charles Cullen, Oxygen dove into the case of Kristen Gilbert during its two-night special, ", after her arrest that as a youngster, She seemed decent and normal - pretty intelligent, sharp.''. Ryan was a full-time musician, master engineer, and record producer. . 113), List of serial killers in the United States, List of medical and pseudo-medical serial killers, "Serial Killer Nurse Who Liked 'Thrill' Of Emergencies Murdered Patients To Impress Boyfriend", "MassLive News - Judge fines Gilbert $1.5 million", "Death Penalty Sought for Nurse in Patients' Deaths - Los Angeles Times", "Lawyers Ask Jury To Spare Gilbert's Life, For Sons' Sake - Hartford Courant", "Nurse reportedly has history of violence", "370 F.3d 95 - Nancy CASCONE, Executrix of the Estate of Michele Cascone, Plaintiff, Appellant, v. UNITED STATES of America, Defendant, Appellee", "Nurse Killed 4 Patients for Thrill, Prosecutor Says", "Botched math hinders murder trial | Amarillo.com | Amarillo Globe-News", "An Uninvited Guest: The Federal Death Penalty and the Massachusetts Prosecution of Nurse Kristen Gilbert", "Lawyers Ask Jury To Spare Gilbert's Life, For Sons' Sake", "181 F3d 152 United States v. Kristen Gilbert", "Nurse On Trial For Patient Deaths - ABC News", "Transcript of remarks given by David Hoose at Ehrmann Awards on May 14, 2001", https://en.wikipedia.org/w/index.php?title=Kristen_Gilbert&oldid=1133991805, American prisoners sentenced to life imprisonment, People convicted of murder by the United States federal government, Prisoners sentenced to life imprisonment by the United States federal government, Short description is different from Wikidata, Pages using infobox criminal with motive parameter, Creative Commons Attribution-ShareAlike License 3.0, 1995 1996 (Gilbert is suspected of deaths dating back to 1989), This page was last edited on 16 January 2023, at 13:33. To divert the attention of the investigators, Gilbert made a hoax call at the hospital about a bomb being planted there. American actress . For these reasons, Gilbert says that the trial judge should have excluded the identifications in this case. 922(q)(1)(A)(1988 ed., Supp. Investigators discovered that Gilbert would inject her victims with epinephrine, sending them into cardiac arrest. Defendant Kristen Gilbert has been indicted on four counts of murder, three counts of attempted murder and six counts of assault with intent to murder, all alleged to have been committed upon patients while she was a nurse at the Veterans Affairs Medical Center (VAMC) in Northampton, Massachusetts. [21] Though Massachusetts does not have capital punishment, her crimes were committed on federal property and thus subject to the death penalty. Get an all-access pass to never-before-seen content, free digital evidence kits, and much more! 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. The night security guard (James G. Perrault) What was Kristen injecting into her patients? Co-workers were taken aback by the couples unprofessional public displays of affection. At the time Gilbert was married. I also want to make it clear because this is close to 404(b) that I'm approaching it as if it were 404(b) evidence in assessing the probative weight versus the unfair prejudice. VA hospital staff members speculated that Gilbert may have been responsible for 350 or more deaths and more than 300 medical emergencies. Terms in this set (5) Who did Kristen have an affair with? From the psychiatric ward, she called Perrault and declared to him I did it! 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. "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. We do not doubt that Gilbert was surprised by the positive voice identification testimony. [12] Because of this, in 1987, she transferred to Mount Wachusett Community College in Gardner, Massachusetts and then to Greenfield Community College in Greenfield, Massachusetts. The nurse allegedly heard the patient cry in pain just before Gilbert exited his room. They all had been under her care at the Veterans Affairs Medical Center at the time of their deaths. She was dutiful and dedicated, just like any good nurse would be, or at least that's what her coworkers believed. On the evening of September 27, Perrault received two anonymous telephone calls while on duty at the security desk. Starting in mid-September Perrault received a number of phone calls at his residence. 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. Oxygen dove into the case of Kristen Gilbert during its two-night special, "Snapped Notorious: Prescription for Death.". She told him that three nurses who worked in Ward C were responsible for starting the investigation and she couldn't understand why they were trying to do this to me. Perrault suggested leaving the area, but Gilbert refused, saying she wanted everybody here to see what they had done to ruin her life. Perrault tried to end their relationship in June of 1996, but she begged him not to do so. A fingerprint from Gilbert's right index finger was lifted from the receiver at the phone booth. Defendant-appellant Kristen Gilbert was charged in a single-count indictment with making a telephone bomb threat on September 26, 1996, to the Department of Veteran's Affairs Medical Center (VAMC) in Leeds, Massachusetts, in violation of 18 U.S.C. 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. The boyfriend, James Perrault, said she once she told him, "I did it! At the start of the trial, prosecutors said Dr. Fredric Rieders would testify that his analysis of tissue samples from the patients proved epinephrine poisoning. [Vol. There was no voice communication, only heavy breathing or hang-ups. Two of the more dramatic witnesses were Gilbert's ex-husband and James Perrault, the policeman with whom she was having an affair at the time of the . She told her former husband (the divorce had become final) that he had the right not to speak to the investigators. Personnel at the VAMC and Perrault received a number of unidentified phone calls over the next several days. She certainly had an opportunity to have her expert perform as many tests on it as necessary. Expert Help. 404(b). It must be borne in mind that part of the government's theory on the voice identification issue was that Gilbert had made the September 30 phone calls on the Talkboy recorder that she bought on September 30 at 6:25 p.m. at Toys-R-Us. 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. Gilbert befriended James Perrault, a hospital police officer whose work schedule roughly corresponded to hers and whose duties required him to respond to medical emergencies in Ward C. . 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. As rumors began to swirl, patients refused to go into Gilbert's ward. movie obituary md dateline crimes deutsch james perrault endocrinologist ubc will denny. Kristen Gilbert was married and had children with her husband, Glenn Gilbert. We make no suggestion that the prosecutor misrepresented the facts or the court erred in accepting the prosecutor's representations. She appeared to have it all: a good nursing job, loving husband and children. That November, Glenn believes his wife tried to kill him, by poisoning his food and later injecting him with a clear liquid which caused him to lose consciousness. 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. The fact that there was an investigation, however, and that for some time it included the defendant, among other persons and things within its scope, is part of the background of this case. Another officer on duty received an anonymous call at 7:35 p.m. Down to the blonde bob, Kristen Gilbert was virtually indistinguishable as the typical mother in the Massachusetts suburb she called home. Janet Knott/The Boston Globe via Getty Images. Exhibit 13 consisted of tape recordings of phone calls made on September 30. Around roughly the same time, the Northampton VAMC was experiencing an increase in the number of fatal heart attacks. She would then respond to the coded emergency, often resuscitating the patients herself. She admitted to Perrault that she watched from across the street as the building which the caller said contained three explosive devices was evacuated. der Trial of Kristen Gilbert Offered an Unsettling Lesson--and Inescapable Conclusion- About the Ultimate Cost of the Death Penalty, BOSTON GLOBE, July 8, 2001, at D2, avail- able at 2001 WLNR 2280523. Kristen Gilbert was an ordinary and well-liked nurse at least at first at the Veteran Affairs Medical Center (VAMC) in Northampton, Massachusetts, (via Oxygen). Nancy and son Jeff Cutting, the family of Kenneth Cutting, when Gilbert was found guilty of murderingthe former soldier. Gilbert's parents, Richard and Claudia Strickland, of Setauket, N.Y., sat behind her in the courtroom. [9][10] As she entered her teenage years, friends and family noticed that she had a habit of lying. Perrault testified against Kristen Gilbert, saying that she confessed at least one murder to him. Kristen H. Gilbert Information researched and summarized by Elizabeth Daly, Kanika Davis, Sarah DeHart, & Michael Palmadesso . In the Summer of 1995, Kristen became friendly with a police officer at the Department of Veteran's Affairs Medical Center named James Perrault. Now 50 years old, she is now serving out her sentence at the Federal Medical Center, Carswell in Fort Worth, Texas. After listening to the tape recordings of the ten phone calls made on the evening of September 26, 1996, the first of which was the bomb threat, Perrault believed that they all were made by Gilbert. Massachusetts banned capital punishment in 1984. James and Kristen became so close that Kristen left her husband for James, but James ended it before it got any more serious. Kristen Gilbert veken t polnknt dolgozott, de gyakran ahelyett, hogy az emberek gygyulst segtette volna, a tlvilgra kldte ket. 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. Suspisions Act At some point in this month, Gilbert offers drugs to a nurse who has asthma. V). He also noticed that the calls seemed directed at him personally. She was also charged with attempted murder, retaliating against a federal witness, and obstructing justice. There was no audible reaction in the courtroom as the decision to spare Gilbert was announced. She argues before us that its admission violated the provisions of Fed.R.Evid. She told Perrault her husband physically abused her, a claim Glenn Gilbert fervently denies. Perrault called Gilbert at 5:12 p.m. and left a message on her answering machine that he would be at the security desk until 7:00 p.m. Perrault received a series of anonymous phone calls at 5:25 p.m., 5:41 p.m., 5:44 p.m., and 6:37 p.m. James Perrault Assistant Vice President, Client Operations at State Street Franklin, Massachusetts, United States 307 connections Trooper Murphy radioed to Special Agent Plante (a member of the surveillance team). [9][14] She graduated from the latter with a nursing diploma, becoming a registered nurse in 1988. She once even left an ex-boyfriend a note in which she claimed to have eaten glass and lied about a suicide attempt. Kristen Heather Gilbert ( ne Strickland; born November 13, 1967) is an American serial killer and former nurse who was convicted of four murders and two attempted murders of patients admitted to the Veterans Affairs Medical Center (VAMC) in Northampton, Massachusetts. CONCORD, NH - For now, the deadly drug pipeline between Manchester and Lawrence, Mass., has been cut off.. April saw the culmination of a year-long drug investigation by multiple agencies, bringing in a huge haul for law enforcement officials - 45 people arrested in two sweeps netting 30 kilograms (more than 60 pounds) of fentanyl, plus two guns and $500,000 in cash. In 1989, Gilbert joined the staff of the Veterans Affairs Medical Center in Northampton. It expressed doubt that the investigation evidence. The court sustained Gilbert's objection, subject to a change of ruling if the government obtained an expert witness. Beginning in the summer of 1995, Gilbert befriended James Perrault, a hospital police officer whose work schedule roughly corresponded to hers and whose duties required him to respond to medical emergencies in Ward C. By fall, Gilbert was having an extramarital affair with Perrault. She also allegedly liked the "thrill" of medical emergencies. She excelled at school and was a member of the math club. As a result of the bomb threat, fifty acutely ill patients were moved by wheelchairs and stretchers from the building containing Ward C and Ward C Annex to another building several hundred yards away. On the same evening, there were unidentified phone calls made to various departments of the VAMC. Preparatory to testifying, he speeded up the play back so that Gilbert's natural voice was heard. I want to make it clear that in permitting evidence of the other investigation to come in, I do find that it has special relevance in this case both on the issues of motive and identity, and that special relevance is entirely separate from any improper purpose that the evidence might be offered for, meaning propensity evidence. She lived in the suburbs of Massachutes, was a recent newly-wed and . 2243, 53 L.Ed.2d 140 (1977), cf. 1624. 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. He survived the incident, though not without great reservations about his wife. 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. Kristen, in a phone call, confessed to her husband Glen that she killed her patients. at 670, 115 S.Ct. 844(e). He described the caller as sounding hurt, upset, taunting, provocative, cold, and unfeeling. "She was e-mailing her lover while my son was there dying," Julia Hudon said. Friends and former beaus, however, said she was also a habitual liar, thief and manipulative person. I did it! "I don't care whether it was first degree or second degree, though the death penalty wouldn't have bothered me because she took my father's life. Gilbert declined the continuance but accepted the court's offer to allow her expert to testify out of order. Gilbert was born Kristen Heather Strickland in Fall River, Massachusetts, on November 13, 1967, the elder of Richard and Claudia Strickland's two daughters. Loveridge v. Dreagoux, 678 F.2d 870, 874 (10th Cir.1982), held: [P]roof of intrastate telephonic messages in connection with the employment of deceptive devices or contrivances is sufficient to confer jurisdiction in a 10(b) and Rule 10b-5 action. In Alley v. Miramon, 614 F.2d 1372, 1379 (5th Cir.1980) the court held: This court has consistently held that the intrastate use of the telephone may confer jurisdiction over a private action under Section 10(b) and Rule 10b-5. In Kerbs v. Fall River Indus., Inc., 502 F.2d 731 (10th Cir.1974) the court explained cogently the reason for the telephone-call rule: Both intrastate and interstate telephone communications are part of an aggregate telephonic system as a whole. 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. As the affair flourished, her marriage to Glenn Gilbert collapsed. Whether to try and save them or simply to watch them die, Gilbert injected them with enough adrenaline for their hearts to race past the breaking point. 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. He was of the opinion that the caller was Gilbert. Allegations of abuse when she was a home health aid, violent threats, and a pattern of manipulation all swirled around Kristen Gilberts blonde head as the investigations into the deaths of the veterans began. Gilbert was convicted in 1998. Consider this evidence only in this light. It may, however, be admissible for other purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident. Gilbert's presence around death in the hospital didn't let up. Female. at 19. Christine Duquette, Henry Hudon's sister, says she wants Gilbert executed. Rule 401 defines relevant evidence. Learn more about FindLaws newsletters, including our terms of use and privacy policy. Shortly after he was released from the hospital, Kristen left her husband and children for Perrault. Gilbert was upset by the investigation and made her feelings known. 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 1988, she married boyfriend Glenn Gilbert, with whom she would have two sons, and became a registered nurse. On the surface, she Kristen seemed to live a happy life. Kristen Gilbert Biography. Perrault believed that the voice on these calls was the same as the one that had made the bomb threat calls. But later, Gilbert told him she was only trying to make him angry, Perrault said. She was well-liked by her co-workers, who remember her organizing the yearly Secret Santa for staff and gift drives for disadvantaged families. Around the same time that she quit her job, she was in and out of the psychiatric department for treatment. They were breaking up at the time. 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. Match. You wanted to know. Gilbert was one of the targets of the investigation. Kristen Gilbert was charged with three counts of murder in a federal grand jury indictment unsealed Tuesday. She is alsoaccused of trying to kill three other patients. Prosecutors said she used epinephrine, a drug that can overstimulate the heart, on all five patients. There are cases directly on point: United States v. Kunzman, 54 F.3d 1522, 1527 (10th Cir.1995), held: As long as the instrumentality used is itself an integral part of an interstate system, Congress may regulate intrastate activities involving the use of the instrumentality under the federal securities laws.. Family members of the victims let out gasps of relief. I did it. 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. Nearly two years after that separate investigation first began, there is still no sufficient evidence that any wrongful act was ever committed by anyone. 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. John Blanding/The Boston Globe via Getty Images. In the present case, we are dealing instead with the second category. Contact us. There are three issues for review: (1) Was there subject matter jurisdiction under the interstate commerce clause; (2) Did the district court commit reversible error in the exclusion and allowance of certain evidence; (3) Was the evidence sufficient under the reasonable doubt standard to sustain the jury's finding of guilt. However, a series of unusual deaths started to take place at the hospital where she was working. Kristen Gilbert, a 33-year-old mother of two, could get the death penalty. 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 fact, she had met him there on several prior occasions, without notice beforehand. All should have been well, but this kind of life, perhaps, was not quite up to Gilberts standards. The court decided to admit the evidence but gave Gilbert several options among which was a short continuance. After a few weeks of just flirting back and forth, we were down at the VFW, and after the VFW closed, I walked her out to her vehicle and we had a kiss, said Perrault. Match. Gilbert objected on the grounds already stated. And proof of motive is one of the purposes for admitting evidence that would be otherwise excludable under Rule 404(b). Friends and former beaus, however, said she was also a habitual liar, thief and manipulative person. They almost all occurred in Ward C, the area where Gilbert worked. Jump into read her life Facts, Wikipedia and biographies Details . So I want to make sure that my specific findings are on the record to the extent that we are in the area of Rule 404(b). [16], Gilbert left the hospital in 1996 amid a hospital investigation into the many suspicious patient deaths that occurred during her shifts. The testimony of the recipients was that the voice sounded as being electronically altered or was a mechanical sounding voice. In 2001, American serial killer and former nurse Kristen Gilbert was convicted of killing four of her patients. Gilbert called a neighbor of hers on two occasions to ask if Perrault had been checking on her. Here, the witnesses were both familiar with Gilbert's voice and therefore had a solid basis for their opinion that the taped voice was Gilbert's, and the defense was free to bring out on cross-examination any aspects of suggestiveness, including the pretrial exposure of the witnesses to the tape. View Kristen Gilbert.docx from AA 1 Running Head: Kristen Gilbert Fisher 1 Kristen Gilbert, born Kristen Strickland on November 13th 1997 would soon be known as the 'Angel of Death'. 1732, 131 L.Ed.2d 714 (1995). 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.. Gilbert knew that Perrault usually stopped at that VFW on the way home from work. I did it. Soon after, she landed a job at Northamptons. Your California Privacy Rights / Privacy Policy. Kristen seemed to be a family woman, living a happy life. After he had spoken to them anyway, she became angry and upset. Personal Life While married to Glenn Gilbert, Kristen developed an affair with the hospital's newly hired security guard, James G. Perrault. While in college at Bridgewater State College in 1984, a young Gilbert suffered psychiatric episodes in which she made violent threats against herself and others. Before starting our legal analysis, we address the government's suggestion that Gilbert's claim was procedurally defaulted and is reviewable only for plain error.

List Of Predatory Journals 2021 Pdf, What Does Ronaldo Eat Before A Match, Grupos De Whatsapp Para Ayuda Economica, Articles K