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.
Preview
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024
Jesse B. Baldwin, Esq.
jbaldwin@acbfirm.com
July 13, 2023
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:
On behalf of Eucharia Nasah, RN, we write in continuance of her cooperation with your office and
your inquiry about Nurse Nasah’s education and qualifications. Nurse Nasah has been licensed as
an RN in New York State since October 31, 2018. Enclosed herewith is a jump drive with
materials we have gathered to demonstrate Nurse Nasah’s qualifications and competence. Also
enclosed is an index of those materials, to help with your review, attached as Exhibit A.
Our prior correspondence
As a reminder, we sent you correspondence on February 14, 2023, advising that this office had
been retained by several nurses who received correspondence from you regarding the nursing
schools they attended in Florida and demanding that they surrender their licenses. A copy of our
February 14 letter, with a copy of the attachment identifying our clients (including Eucharia
Nasah), is attached as Exhibit B. We have written you several subsequent letters as additional
nurses retained us after receiving similar correspondence from you. We have received no response
to any of our letters, even though each of them indicates an intention to cooperate and requests a
conference to discuss a reasonable resolution of these matters.
5680 Main Street | Buffalo, New York 14221
716-475-9533 | www.acbfirm.com
EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024
No grounds for summary suspension
As briefly described in our prior letter, there are no grounds for a summary suspension of Nurse
Nasah’s license. This nurse poses no threat to the public health imperatively requiring emergency
action. (See Commissioner’s Reg. 17.9). Nurse Nasah neither committed nor knowingly
participated in any fraud. As described more fully below and in the enclosed materials, Nurse
Nasah did attend and complete a nursing education program at Med Life Institute WBP n/k/a Palm
Beach School of Nursing. The program included classroom instruction and clinical
training. Nurse Nasah passed the NCLEX. The fact that a nursing school attended by this nurse
may have also sold or given out fraudulent degrees to other students does not render this nurse a
threat to the public health. We believe your office is aware of this fact, since five months have
passed since your initial letter to Nurse Nasah and no direct action has been taken, nor has any
proceeding been commenced against this nurse’s license.
No misconduct or other grounds for discipline
Nurse Nasah is entitled to retain her RN license. She obtained this license in full compliance with
applicable law. She completed the educational requirement for licensure in accordance with
Commissioner’s Reg. 52.12(a)(2) by completing a program in nursing approved by the licensing
authority of Florida for practice as a Registered Professional Nurse. She was authorized to sit for
the NCLEX and passed the exam. These were the legal requirements for obtaining a New York
RN license at that time. Any changes to the regulation(s) since then are not retroactive to when
this nurse applied for and received her license. Absent any fraud on her part, there is no basis to
take her license from her.
Nurse Nasah has clearly and obviously committed no fraud. The degree she obtained from Med
Life Institute WBP n/k/a Palm Beach School of Nursing (Hereinafter “PBSON”) was not
purchased; it was earned. Prior to attending PBSON, she completed a Practical Nursing program
through Med Life Institute in Georgia, passed her NCLEX-PN and received her LPN in the State
of North Carolina. Nurse Nasah earned 60.00 credit hours at Georgia Perimeter College, as well
as 13.00 credit hours at Gwinnett Technical College. Documents related to her prior education are
contained at Exhibit A on the jump drive included with this letter.
As part of her application process to PBSON, Nurse Nasah submitted transcripts of her PN
program and prior college credits, along with completing an entrance exam. She attended more
than 10 in person classes, all of which were held in Florida. She retained some of her course
presentation materials, which are included at Exhibit B on the jump drive. Her RN education
included quizzes and examinations, including the requirement to pass an exit exam to complete
the program. Confirmation of her travel expenses to Florida are also included in Exhibit B.
Nurse Nasah completed at least 255 clinical/lab simulation hours in Florida. She completed 510
additional hours as verified by a preceptor. Evidence of completion of her clinical hours is
contained at Exhibit B.1.b. Prior to attending PBSON, she completed 768 clinical hours during
her Practical Nursing program. (Exhibit A.3)
.
2
EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024
Given these facts, it cannot reasonably be suggested that Nurse Nasah participated in any fraud or
made any material misrepresentations on her license application materials.
Nurse Nasah’s competence as an RN is established
Nurse Nasah has completed continuing education credits including: Infection Control Training for
Healthcare Professionals in New York State (8/2021) and Florida Nurse CE Package – 30 credit
hours (2/2023) (Exhibit E)
Since earning her RN, Nurse Nasah worked as an RN with ARC Schenectady (2019-2022) and
Encompass Rehabilitation Hospital (2022- 2023) where she provided direct patient care. Her job
duties included administering medications; providing other measures for symptom alleviation;
collaborating with other professionals to optimize patient care and comfort; carry out orders of
medical doctors; assess individuals with intellectual disability with acute or any change in
condition; telephone triage and send patient to hospital based on assessment; certify direct support
staff to be able to administer oral and subcutaneous medications; as well as work as a nurse case
manager.
Accompanying this submission is a letter from Alyson Ligon, RN, Director of Nursing at
Schenectary ARC who, in commenting on Nurse Nasah’s abilities, writes:
“Eucharia managed care for individuals in residential programs,
provided training for direct support professionals and certified staff
in medication administration. *** She was also responsible for
being on call for approximately 150 individuals to provide
telephone triage on evenings and weekends … Eucharia quickly
developed into a competent and professional nurse who was a true
asset to the organization. Eucharia is a great nurse …”
(Exhibit F)(emphasis added)
Conclusion
For the reasons stated above, and based on the evidence enclosed, it is clear Nurse Nasah lawfully
obtained her nursing license and has gone on to provide competent and professional nursing
services. We respectfully submit that it would be consistent with the Department’s mandate to
protect, rather than destroy, this nurse’s ability to practice.
3
EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024
To avoid misconduct charges and a plenary hearing, we are willing, even eager, to discuss a way
to resolve this issue and address the Department’s concerns regarding Nurse Nasah’s education
and training. Please call or email me anytime to have that discussion.
Very truly yours,
ADDELMAN CROSS & BALDWIN, PC
Jesse B. Baldwin
JBB/ba
4
EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024
INDEX OF SUPPORTING DOCUMENTATION
ON BEHALF OF
EUCHARIA NWEGAUH NASAH, RN
School Attended: Med-Life Institute n/k/a Palm Beach School of Nursing
Dates of Attendance: 1/11/2016 – 9/22/2017
A. Prior Education
1. Gwinnett Technical College
a. Transcript
2. Georgia Perimeter College
a. Transcript
b. Dean’s List Certificate
3. Med Life Institute (Georgia) – Practical Nursing
a. Transcript
B. Med-Life Institute n/k/a Palm Beach School of Nursing, Associates of Science of Nursing
1. Documents specific to Eucharia Nwegauh Nasah
a. Official Transcript, dates attended: 1/11/2016 – 9/22/2017
b. Clinical Documentation
i. Skills Lab
ii. Pediatrics
iii. Pscyh
c. Evidence of travel expenses in Florida
i. Bank statements evidencing payments made in Florida
ii. Flight receipts
2. General Admission Documents
a. Welcome Letter
b. 2015 – 2016 Admission Requirements
c. Application
d. Admissions Checklist
e. Tuition & Fees
f. Holidays Observed
g. Physician Statement
h. Drug Screening Request
3. General Course Materials
a. Nursing Care Plan form
b. Clinical Forms
1
EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024
c. Course Syllabuses
i. NUR 100, LPN to RN Transition, Course Syllabus 2016
ii. NUR 101, Introduction to Health Care, Course Syllabus 2016
iii. NUR 103 Pharmacology, Course Syllabus 2016
iv. NUR 104, Critical Thinking and the Nursing Process, Course Syllabus
2016
v. NUR 201, Adult Nursing I, Winter Course Syllabus 2016
vi. NUR 205, Maternal Newborn Nursing, Course Syllabus 2016
vii. NUR 207, Pediatric Nursing, Course Syllabus 2016
viii. NUR 301, Adult Nursing II, Course Syllabus 2016
ix. NUR 402 Professional Nursing Leadership, Course Syllabus 2016
x. HSC 104 Pathophysiology, Course Syllabus 2016
C. NCLEX documents
1. Authorization to Test, test validity 22 February 2018 – 23 May 2018
D. Registered Professional Nurse
1. New York License Number 760472, issued 10/31/2018
2. Registration Certificates, valid through 8/31/2024 and 9/30/2021
3. Florida RN license
E. Evidence of Continuing Education
1. Infection Control Training for Healthcare Professionals in NYS, 8/12/2021
2. Florida Nurse CE Package – 30 credit hours, 2/1/2023
F. Letters of Support
1. Letter from Alyson Ligon, RN, Director of Nursing, Schenectady ARC
• “Eucharia managed care for individuals in residential programs, provided
training for direct support professionals and certified staff in medication
administration. *** She was also responsible for being on call for
approximately 150 individuals to provide telephone triage on evenings and
weekends … Eucharia quickly developed into a competent and professional
nurse who was a true asset to the organization. Eucharia is a great nurse …”
2
EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024
From: Beth Atwood
To: OPDPLS
Cc: Jesse Baldwin
Subject: Eucharia Nasah RN License No. 760427
Date: Thursday, July 13, 2023 4:15:00 PM
Attachments: 2.13.2023 JBB - Hamilton w exhibits_Redacted.pdf
image001.png
7.13.2023 JB - Hamilton Nasah__Eucharia_-_Submission_letter_NY_OP.pdf
INDEX_OF_SUPPORTING_DOCUMENTATION_-_Eucharia__Nasah.pdf
Dear Mr. Hamilton:
Attached please find correspondence from attorney Jesse Baldwin concerning our client, Eucharia
Nasah, RN license number 760427. Also attached is our prior correspondence of February 14, 2023
(Exhibit A) and an index of supporting documentation (Exhibit B).
A hard copy of the letter with a jump drive containing the supporting documents will be mailed to
you today.
Thank you for your consideration.
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 H - Nasah, E - 7.12.2023 Baldwin -NYSED
Preview
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024 Jesse B. Baldwin, Esq. jbaldwin@acbfirm.com July 13, 2023 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: On behalf of Eucharia Nasah, RN, we write in continuance of her cooperation with your office and your inquiry about Nurse Nasah’s education and qualifications. Nurse Nasah has been licensed as an RN in New York State since October 31, 2018. Enclosed herewith is a jump drive with materials we have gathered to demonstrate Nurse Nasah’s qualifications and competence. Also enclosed is an index of those materials, to help with your review, attached as Exhibit A. Our prior correspondence As a reminder, we sent you correspondence on February 14, 2023, advising that this office had been retained by several nurses who received correspondence from you regarding the nursing schools they attended in Florida and demanding that they surrender their licenses. A copy of our February 14 letter, with a copy of the attachment identifying our clients (including Eucharia Nasah), is attached as Exhibit B. We have written you several subsequent letters as additional nurses retained us after receiving similar correspondence from you. We have received no response to any of our letters, even though each of them indicates an intention to cooperate and requests a conference to discuss a reasonable resolution of these matters. 5680 Main Street | Buffalo, New York 14221 716-475-9533 | www.acbfirm.com EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024 No grounds for summary suspension As briefly described in our prior letter, there are no grounds for a summary suspension of Nurse Nasah’s license. This nurse poses no threat to the public health imperatively requiring emergency action. (See Commissioner’s Reg. 17.9). Nurse Nasah neither committed nor knowingly participated in any fraud. As described more fully below and in the enclosed materials, Nurse Nasah did attend and complete a nursing education program at Med Life Institute WBP n/k/a Palm Beach School of Nursing. The program included classroom instruction and clinical training. Nurse Nasah passed the NCLEX. The fact that a nursing school attended by this nurse may have also sold or given out fraudulent degrees to other students does not render this nurse a threat to the public health. We believe your office is aware of this fact, since five months have passed since your initial letter to Nurse Nasah and no direct action has been taken, nor has any proceeding been commenced against this nurse’s license. No misconduct or other grounds for discipline Nurse Nasah is entitled to retain her RN license. She obtained this license in full compliance with applicable law. She completed the educational requirement for licensure in accordance with Commissioner’s Reg. 52.12(a)(2) by completing a program in nursing approved by the licensing authority of Florida for practice as a Registered Professional Nurse. She was authorized to sit for the NCLEX and passed the exam. These were the legal requirements for obtaining a New York RN license at that time. Any changes to the regulation(s) since then are not retroactive to when this nurse applied for and received her license. Absent any fraud on her part, there is no basis to take her license from her. Nurse Nasah has clearly and obviously committed no fraud. The degree she obtained from Med Life Institute WBP n/k/a Palm Beach School of Nursing (Hereinafter “PBSON”) was not purchased; it was earned. Prior to attending PBSON, she completed a Practical Nursing program through Med Life Institute in Georgia, passed her NCLEX-PN and received her LPN in the State of North Carolina. Nurse Nasah earned 60.00 credit hours at Georgia Perimeter College, as well as 13.00 credit hours at Gwinnett Technical College. Documents related to her prior education are contained at Exhibit A on the jump drive included with this letter. As part of her application process to PBSON, Nurse Nasah submitted transcripts of her PN program and prior college credits, along with completing an entrance exam. She attended more than 10 in person classes, all of which were held in Florida. She retained some of her course presentation materials, which are included at Exhibit B on the jump drive. Her RN education included quizzes and examinations, including the requirement to pass an exit exam to complete the program. Confirmation of her travel expenses to Florida are also included in Exhibit B. Nurse Nasah completed at least 255 clinical/lab simulation hours in Florida. She completed 510 additional hours as verified by a preceptor. Evidence of completion of her clinical hours is contained at Exhibit B.1.b. Prior to attending PBSON, she completed 768 clinical hours during her Practical Nursing program. (Exhibit A.3) . 2 EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024 Given these facts, it cannot reasonably be suggested that Nurse Nasah participated in any fraud or made any material misrepresentations on her license application materials. Nurse Nasah’s competence as an RN is established Nurse Nasah has completed continuing education credits including: Infection Control Training for Healthcare Professionals in New York State (8/2021) and Florida Nurse CE Package – 30 credit hours (2/2023) (Exhibit E) Since earning her RN, Nurse Nasah worked as an RN with ARC Schenectady (2019-2022) and Encompass Rehabilitation Hospital (2022- 2023) where she provided direct patient care. Her job duties included administering medications; providing other measures for symptom alleviation; collaborating with other professionals to optimize patient care and comfort; carry out orders of medical doctors; assess individuals with intellectual disability with acute or any change in condition; telephone triage and send patient to hospital based on assessment; certify direct support staff to be able to administer oral and subcutaneous medications; as well as work as a nurse case manager. Accompanying this submission is a letter from Alyson Ligon, RN, Director of Nursing at Schenectary ARC who, in commenting on Nurse Nasah’s abilities, writes: “Eucharia managed care for individuals in residential programs, provided training for direct support professionals and certified staff in medication administration. *** She was also responsible for being on call for approximately 150 individuals to provide telephone triage on evenings and weekends … Eucharia quickly developed into a competent and professional nurse who was a true asset to the organization. Eucharia is a great nurse …” (Exhibit F)(emphasis added) Conclusion For the reasons stated above, and based on the evidence enclosed, it is clear Nurse Nasah lawfully obtained her nursing license and has gone on to provide competent and professional nursing services. We respectfully submit that it would be consistent with the Department’s mandate to protect, rather than destroy, this nurse’s ability to practice. 3 EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024 To avoid misconduct charges and a plenary hearing, we are willing, even eager, to discuss a way to resolve this issue and address the Department’s concerns regarding Nurse Nasah’s education and training. Please call or email me anytime to have that discussion. Very truly yours, ADDELMAN CROSS & BALDWIN, PC Jesse B. Baldwin JBB/ba 4 EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024 INDEX OF SUPPORTING DOCUMENTATION ON BEHALF OF EUCHARIA NWEGAUH NASAH, RN School Attended: Med-Life Institute n/k/a Palm Beach School of Nursing Dates of Attendance: 1/11/2016 – 9/22/2017 A. Prior Education 1. Gwinnett Technical College a. Transcript 2. Georgia Perimeter College a. Transcript b. Dean’s List Certificate 3. Med Life Institute (Georgia) – Practical Nursing a. Transcript B. Med-Life Institute n/k/a Palm Beach School of Nursing, Associates of Science of Nursing 1. Documents specific to Eucharia Nwegauh Nasah a. Official Transcript, dates attended: 1/11/2016 – 9/22/2017 b. Clinical Documentation i. Skills Lab ii. Pediatrics iii. Pscyh c. Evidence of travel expenses in Florida i. Bank statements evidencing payments made in Florida ii. Flight receipts 2. General Admission Documents a. Welcome Letter b. 2015 – 2016 Admission Requirements c. Application d. Admissions Checklist e. Tuition & Fees f. Holidays Observed g. Physician Statement h. Drug Screening Request 3. General Course Materials a. Nursing Care Plan form b. Clinical Forms 1 EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024 c. Course Syllabuses i. NUR 100, LPN to RN Transition, Course Syllabus 2016 ii. NUR 101, Introduction to Health Care, Course Syllabus 2016 iii. NUR 103 Pharmacology, Course Syllabus 2016 iv. NUR 104, Critical Thinking and the Nursing Process, Course Syllabus 2016 v. NUR 201, Adult Nursing I, Winter Course Syllabus 2016 vi. NUR 205, Maternal Newborn Nursing, Course Syllabus 2016 vii. NUR 207, Pediatric Nursing, Course Syllabus 2016 viii. NUR 301, Adult Nursing II, Course Syllabus 2016 ix. NUR 402 Professional Nursing Leadership, Course Syllabus 2016 x. HSC 104 Pathophysiology, Course Syllabus 2016 C. NCLEX documents 1. Authorization to Test, test validity 22 February 2018 – 23 May 2018 D. Registered Professional Nurse 1. New York License Number 760472, issued 10/31/2018 2. Registration Certificates, valid through 8/31/2024 and 9/30/2021 3. Florida RN license E. Evidence of Continuing Education 1. Infection Control Training for Healthcare Professionals in NYS, 8/12/2021 2. Florida Nurse CE Package – 30 credit hours, 2/1/2023 F. Letters of Support 1. Letter from Alyson Ligon, RN, Director of Nursing, Schenectady ARC • “Eucharia managed care for individuals in residential programs, provided training for direct support professionals and certified staff in medication administration. *** She was also responsible for being on call for approximately 150 individuals to provide telephone triage on evenings and weekends … Eucharia quickly developed into a competent and professional nurse who was a true asset to the organization. Eucharia is a great nurse …” 2 EXHIBIT H - Nasah, E - 7.12.2023 Baldwin -NYSED FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 02/21/2024 From: Beth Atwood To: OPDPLS Cc: Jesse Baldwin Subject: Eucharia Nasah RN License No. 760427 Date: Thursday, July 13, 2023 4:15:00 PM Attachments: 2.13.2023 JBB - Hamilton w exhibits_Redacted.pdf image001.png 7.13.2023 JB - Hamilton Nasah__Eucharia_-_Submission_letter_NY_OP.pdf INDEX_OF_SUPPORTING_DOCUMENTATION_-_Eucharia__Nasah.pdf Dear Mr. Hamilton: Attached please find correspondence from attorney Jesse Baldwin concerning our client, Eucharia Nasah, RN license number 760427. Also attached is our prior correspondence of February 14, 2023 (Exhibit A) and an index of supporting documentation (Exhibit B). A hard copy of the letter with a jump drive containing the supporting documents will be mailed to you today. Thank you for your consideration. 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 H - Nasah, E - 7.12.2023 Baldwin -NYSED