Excerpt from Government's Brief in Gilbert

Government’s Brief in Gilbert:

. . .

[T]he similarities between the VAMC poisonings and the Glenn Gilbert poisoning compel “an inference of a pattern” that proves that the defendant more likely than not was the perpetrator of the VAMC incidents. The similarities consist of:

1. The defendant chose poisoning, a rare manner of committing murder;

2. The defendant selected a syringe and needle as the way to administer the poisons, a rare means of poisoning;

3. The defendant used the VAMC as the identical source for the syringes and needles due to easy access and lack of accountability;

4. The defendant also picked the VAMC as the identical source for the poisons due to their easy access and lack of accountability;

5. The defendant utilized her position and employment as a nurse at the VAMC to administer the poisons under the guise of an innocuous, routine nursing procedure, i.e., a normal saline flush or the routine administration of insulin, thus creating a false sense of trust that afforded the defendant the necessary access;

 6. The defendant chose clear, odorless drugs - epinephrine and potassium - as poisons because their appearances were consistent with the stated purpose of her ruse to allow the necessary access;

 7. The defendant chose cardiac drugs as the poisons - epinephrine and potassium - because they induced immediate cardiac arrest when administered in excessive amounts;

 8. The defendant selected epinephrine and potassium in particular because these cardiac drugs, when injected in lethal amounts, produced symptoms in the victims consistent with their underlying clinical problems, e.g. drug overdose and heart disease in the VAMC victims, and a potassium abnormality in the case of Glenn Gilbert, thus masking the poisonings and making natural, sudden cardiac death appear plausible;

 9. The defendant also preferred poisons produced naturally by the human body whose presence at heightened levels in a deceased person - epinephrine and insulin in the case of the VAMC victims, and potassium in the case of Glenn Gilbert - would be virtually undetectable, and, if detected at autopsy or upon toxicological screening, plausibly explained by the victim's underlying clinical course, including resuscitation efforts;

10. The defendant poisoned the VAMC victims and Glenn Gilbert in part to promote her relationship with Perrault;

11. The defendant poisoned Glenn Gilbert just three months after her first VAMC victim and only four weeks before her next VAMC victim;

 12. The defendant poisoned the VAMC victims and Glenn Gilbert in the same city, Northampton.

 These similarities . . .  demonstrate . . . [a] fully-established correspondence between the charged and uncharged events.

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