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. 11 RECEIVED NYSCEF: 02/21/2024 Jesse B. Baldwin, Esq. jbaldwin@acbfirm.com February 15, 2023 VIA EMAIL: OPDPLS@nysed.gov David Hamilton, LMSW Assistant Commissioner, OP State Education Department RE: Nursing license inquiry on behalf of Karen Saulong Dear Mr. Hamilton: This office has been retained to represent Karen Saulong. Ms. Saulong received correspondence from you seeking surrender of her license or for her to send transcripts establishing her clinical training at an institution other than one of the Florida nursing schools listed on your letter. I write in response to that correspondence. Ms. Saulong nearly completed a nursing program at an accredited school in New York, where she received all of the necessary clinical training pursuant to the Department’s requirements to become a Registered Professional Nurse in New York. However, she completed her schooling at Palm Beach School of Nursing in Florida. Her credits and clinical training from New York were accepted by Palm Beach. She then attended classes where she received remedial instruction and prepared for the New York Boards. After completing this remedial instruction, Palm Beach School of Nursing certified her as qualified to sit for the New York Boards. Ms. Saulong passed her boards, submitted the required application materials, and received her New York license as a Registered Professional Nurse. She did not commit or knowingly participate in any kind of fraud, and she did not purchase credentials from anyone. In fact, it was a professor at her nursing program in New York who referred her to Palm Beach School of Nursing to complete her certification process so she could sit for the Boards and become licensed in New York. At the time Ms. Saulong became licensed, Palm Beach was an accredited RN training program in the State of Florida, which means she met the legal requirements for licensure in New York pursuant to Commissioner’s Regulation 64.1(a)(2). Ms. Saulong intends to cooperate with the Department to address any concerns you have about her clinical training and qualifications. Ms. Saulong is in the process of obtaining documentation to prove her clinical training in New York, and we request additional time to get 5680 Main Street | Buffalo, New York 14221 716-466-1476 | www.acbfirm.com EXHIBIT J - Saulong, K - 2.15.2023 Baldwin - NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/21/2024 Jesse B. Baldwin, Esq. jbaldwin@acbfirm.com these documents to you. Thirty days would be much appreciated. I respectfully suggest that we should then have a conference to discuss next steps if the Departments still has any concerns or requires anything further. Please contact me anytime to set up a conference to discuss Ms. Saulong’s case. Thank you. Very truly yours, ADDELMAN CROSS & BALDWIN, PC Jesse B. Baldwin JBB/ba 5680 Main Street | Buffalo, New York 14221 716-466-1476 | www.acbfirm.com EXHIBIT J - Saulong, K - 2.15.2023 Baldwin - NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/21/2024 Jesse B. Baldwin, Esq. jbaldwin@acbfirm.com 5680 Main Street | Buffalo, New York 14221 716-466-1476 | www.acbfirm.com EXHIBIT J - Saulong, K - 2.15.2023 Baldwin - NYSED