On February 21, 2024 a Exhibit,Appendix was filed involving a dispute between Aderonke Ojerinde, Alice Kwane Frempong, Anita Barbara Asamoah, Awal Mohammad Rahaman, Bartholomew Ezem, Beatrice Leste, Brenda Andrews, Camille Alexa Joasil, Celestine Chi Aririguzoh, Charity Akakpo, Charyl Pilgrim, Christian Nwankwo, Elizabeth King-Nabi, Emmanuel Tetteh, Ese Okoko, Eucharia Nweguah Nasah, Frances Linda Ojeifo, Gaytreedebie Boedhai, Jacqueline Boamah-Bright, Jennifer Okoro, Joana Amoafo Dofoo, Johan Nesbitt, Johnnet Korvah, Jolette Pasteur, Joyce Chambers, Julene Alexander, Kadiatu Sei-Bureh, Karen Saulong, Keshia Porter, Lisabeth Johnson, Louise Gelin, Mabel Boakye, Marcus Fairclough, Maria Sokolo, Mark Gyau, Miatta Soko, Micaela Haywood, Mike Jenny Veillard, Nneka Nzekwu, Okema Torey, Omehvy George, Prince Adeparusi, Rebecca Agyeiwaa Annoh, Regina Nkechi Emmanuel, Rose Freeman, Salamat Yusifu, Scholastica Tandongfor, Soeurette Colin, Sofia Lamarre, Sonia Jones, Stella Agyenim Boateng, Sunday Odeh, Theodora Alexander, Veronique Lahens, and Betty A. Rosa In Her Capacity As Commissioner Of The New York State Education Department, David Hamilton In His Official Capacity As The Assistant Commissioner For Professional Licensing And Practice For The Nys Dept. Of Education Office Of Professions, New York State Education Department, New York State Office Of The Professions, Sarah Benson In Her Official Capacity As Deputy Commissioner Of The Nys Dept. Of Education And As The Official Heading The Office Of The Professions, for Special Proceedings - CPLR Article 78 in the District Court of Albany County.
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FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 02/21/2024 Jesse B. Baldwin, Esq. jbaldwin@acbfirm.com January 10, 2024 VIA EMAIL: OPDPLS@nysed.gov and USPS David Hamilton, LMSW Assistant Commissioner, OP State Education Department DPLS Director’s Office 89 Washington Avenue Albany, New York 12234-1000 RE: Eucharia Nasah RN License No. 760427 Dear Mr. Hamilton: We write to supplement our prior submissions on behalf of Eucharia Nasah. On June 29, 2023, the Florida Department of Health Probable Cause Panel reviewed Ms. Nasah’s case and dismissed the case, taking away any doubts about the efficacy of her nursing education or qualifications. A copy of the letter from the Florida Department of Health is attached hereto as Exhibit A. As a reminder, you wrote two emails to Ms. Nasah directing her to surrender her license by mailing it to you and stating that you have determined her education was not satisfactory. We believe this determination was made not only without providing Ms. Nasah with the due process required by both the Education Law and the United States Constitution, but also without making any effort to examine Nurse Nasah’s individual case. The Florida Department of Health, which governs credentialing of the institution where she received the education you have called into question, has conducted an actual investigation both into the school and into Nurse Nasah’s individual case, and has cleared her Florida license of any challenge. 5680 Main Street | Buffalo, New York 14221 716-475-9533 | www.acbfirm.com EXHIBIT I - Nasah, E - 1.10.2024 Baldwin - NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 02/21/2024 We ask you to consider this important evidence before taking any action against Ms. Nasah’s New York nursing license, and we ask again that you contact the undersigned to discuss resolution that would address your concerns without subjecting Ms. Nasah to any proceedings. Very truly yours, ADDELMAN CROSS & BALDWIN, PC Jesse B. Baldwin JB/ba Enc. EXHIBIT I - Nasah, E - 1.10.2024 Baldwin - NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 02/21/2024 Mission: Ron Desantis To protect, promote & improve the health Governor of all people In Florida through integrated state, county & community effoJ1s. Aoriaa HEALTH Joseph A. Ladapo, MD, PhD State Surgeon General Vision: To be the Healthiest State In the Nation July 15, 2023 George Indest, Esq. 1101 Douglas Avenue, Ste 1000 Altamonte Springs, FL 32714 Re: DOH vs. Eucharia Nasah, R.N. DOH Case Number: 2023-08639 Dear Mr. Indest: Please be advised that on June 29, 2023, the Probable Cause Panel for the Board of Nursing again reviewed the complaint referenced above. At the meeting, the Panel reconsidered its previous finding of probable cause and determined that this case should be dismissed. Thank you for your patience in the investigation of this matter. Sincerely, Caitlin Harden, Esq. Assistant General Counsel CH/ajp Florida Department of Health Office of the General Counsel - Prosecution SeNices Unit 4052 Bald Cypress Way, Bin C.05 • Tallahassee, FL 32399-3265 Accredited Health Department EXPRESS MAIL: 2585 Merchan1s Row, Suite 105 • Public Health Accreditation Board PHONE: 850/245-4640 • FAX: 850/245-4662 FlorldaHealth.gov EXHIBIT I - Nasah, E - 1.10.2024 Baldwin - NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 02/21/2024 From: Beth Atwood To: OPDPLS Cc: Jesse Baldwin Subject: Eucharia Nasah, RN License No. 760427 - supplemental letter Date: Wednesday, January 10, 2024 10:49:00 AM Attachments: Nasah 1.10.2024 JB - Hamilton supplement w FL decision.pdf image001.png Dear Mr. Hamilton – Attached is supplemental correspondence from attorney Jesse Baldwin concerning our client Eucharia Nasah, RN License No. 760427. Thank you. Beth Atwood | Litigation Paralegal Addelman Cross & Baldwin, PC 5680 Main Street | Buffalo, New York 14221 716-466-1476 | batwood@acbfirm.com | www.acbfirm.com Statement of Confidentiality: This electronic message may contain privileged or confidential information. If you are not the intended recipient of this e-mail, please delete it from your system and advise the sender. EXHIBIT I - Nasah, E - 1.10.2024 Baldwin - NYSED