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. 57 RECEIVED NYSCEF: 02/21/2024
Jesse B. Baldwin, Esq.
jbaldwin@acbfirm.com
October 30, 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: Salamat Eniola Yusifu
RN License No. 763308
Dear Mr. Hamilton:
On behalf of Salamat Yusifu, RN/BSN, we write continuance of cooperation with your office and
your inquiry about our client’s education and qualifications. Nurse Yusifu has been licensed as an
RN in New York State since January 18, 2019. Enclosed herewith is a jump drive with materials
we have gathered to demonstrate Nurse Yusifu’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 Salamat
Yusifu), 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 DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 57 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
Yusifu’s license. This nurse poses no threat to the public health imperatively requiring emergency
action. (See Commissioner’s Reg. 17.9). She neither committed nor knowingly participated in
any fraud. As described more fully below and in the enclosed materials, Nurse Yusifu did attend
and complete a nursing education program at Palm Beach School of Nursing. The program
included classroom instruction and clinical training. Nurse Yusifu passed the NCLEX. The fact
that a nursing school attended by this nurse may have sold or given out fraudulent degrees to other
students does not render this particular nurse a threat to the public health. We believe your office
is aware of this fact, since more eight months have passed since your initial letter to Nurse Yusifu
and no direct action has been taken, nor has any proceeding been commenced against her license.
No misconduct or other grounds for discipline
Nurse Yusifu 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 are the legal requirements for obtaining her RN license.
Absent any fraud on her part, there is no basis to take her license from her.
Nurse Yusifu has clearly and obviously committed no fraud. The degree she obtained from Palm
Beach School of Nursing (hereinafter PBSON) was not purchased; it was earned. Prior to
attending PBSON, Nurse Yusifu completed her LPN training at Best Care Training Institute in
New Jersey, passed her NCLEX-PN and was licensed as an LPN in the State of New York. She
also earned 42.50 credit hours, while maintaining a cumulative GPA of 3.574, as a nursing major
at Hostos Community College. Documents related to her LPN are contained in Exhibit A and her
transcript from Hostos Community College are contained in Exhibit B on the materials on the jump
drive provided with this correspondence.
Her LPN license and transcripts of previous education were included as part of her application
process to PBSON. She was also required to take an entrance examination. She attended more
than 30 classes, at least half of which were in person. The rest were online. She retained some of
her course presentation materials, which are included at Exhibit C. Her RN education included
quizzes and examinations. Her transcript evaluation form, acceptance letter, email
communications with school representatives concerning a finished class, proof of payment,
photographs of Nurse Yusifu at the PBSON learning center, as well as proof of travel expenses in
Florida are also included at Exhibit C.
Nurse Yusifu completed 80 clinical hours at a hospital in Florida, an additional 30 clinical hours
at the school’s lab/stimulus class, and an additional 90 clinical hours supervised and verified by a
preceptor. Prior to PBSON, she completed 610 clinical hours during her LPN training.
2
EXHIBIT DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024
Given these facts, it cannot reasonably be suggested that Nurse Yusifu participated in any fraud or
made any material misrepresentations on her license application materials.
Nurse Yusifu’s competence as an RN is established
In addition to the education discussed above, Nurse Yusifu continued her nursing education and
completed her Bachelor of Science in Nursing, Summa Cum Laude, from Aspen University in
2020. (Exhibit F)
Prior to obtaining her RN, beginning in 2013, Nurse Yusifu worked as an LPN in positions
involving direct patient care at Pioneer Home (2013-2015), RCM Technology (2015 – 2017) and
Montefiore Family Care Center (2018-2019). Her duties included monitoring patient vital signs;
maintaining cleanliness and comfort of each patient, including bathing, feeding and dressing;
assisting nursing and medical staff with basic medical tasks, such as administering medication,
evaluating the patient's wellbeing, reporting any needs to medical staff, changing dressings and
bandages, and ensuring patients are healing properly.
Since obtaining her RN license in 2019, Nurse Yusifu has worked as an RN in several positions
rendering care to patients. These include the Institute for Family Health (2019-2021), Morris
Heights Health Center (2021-2022) and Helping U Home Care Agency (2019-2023). She rendered
direct patient care in each of these positions with duties including monitoring and coordinating the
daily patient care activities of the unit; scheduling staff and patients to ensure full coverage of
patient care needs at all times and to ensure effective patient services; provide triage advice and
guidance to patients; administering and monitoring medications; assisting patients with activities
of daily living including feeding, dressing and bathing; performing basic and advanced life
support, end of life care, physical examinations, and vital signs checks; and preparing patients for
bedside procedures and surgeries.
In addition to her professional education and training, Nurse Yusifu’s competence has been
recognized by the New York State Assembly, who presented her with a citation on May 13, 2022
for her work at Morris Heights Health Center. The citation states that “… the leadership, tenacity
and perseverance Nurse Salamat has, so often goes unrecognized and unrewarded” and recognizes
Salamat Yusifu not only as a competent nurse, but as an “outstanding Nurse.” Additionally, Nurse
Yusifu received a Certificate of Appreciation in Recognition of Dedicated Service in May 2022.
(Exhibit G)
Conclusion
For the reasons stated above, and based on the evidence enclosed, it is clear Salamat Yusifu
lawfully obtained her nursing license has gone on to advance her training and to provide
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 DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024
To avoid misconduct charges and a plenary hearing, we are happy to discuss a way to resolve this
issue and address the Department’s concerns regarding Nurse Yusifu’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 DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024
INDEX OF SUPPORTING DOCUMENTATION
ON BEHALF OF
SALAMAT ENIOLA YUSIFU, RN
A. Licensed Practical Nurse
1. New York State License No. 316868, issued 10/28/2013
2. New York State LPN Registration Certificate, valid through 8/31/2022
3. Best Care Training Institute, LPN Program
a. Transcript
b. Diploma
B. Previous Education
1. Hostos County Community College – nursing major
a. Transcript
C. Palm Beach School of Nursing, Associates of Science of Nursing
1. Documents specific to Salamat Yusifu
a. Official Transcript
b. Associate of Science in Nursing, Degree
c. Transcript Evaluation Form
d. Acceptance letter
e. Receipts
f. Email message, 5.21.2018, concerning finished class
g. Learning Center photographs
h. Evidence of travel expenses in Florida
i. Car Rental, March 31, 2018
2. General Orientation Documents
a. General Orientation Information
b. Application Information
c. RN Program Breakdown By Course
d. RN Booklist
e. Clinical Location Disclosure
f. RN Checklist
g. Enrollment Agreement
h. Physical Assessment Form
i. Hep B and Flu Declination
3. Course Materials
a. Chapter 16 – Care of Preoperative Patients
b. Chapter 17 - Care of Intraoperative Patients
1
EXHIBIT DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024
c. Chapter 18 – Care of Postoperative Patients
d. Chapter 22 – Care of patients with Immune Function Excess: Hypersensitivity
(Allergy) and Autoimmunity
e. Chapter 23 – Cancer Development
f. Chapter 24 – Care of Patients with Cancer
g. Chapter 25 – Care of Patients with Infection
h. Chapter 26 – Assessment of the Skin, Hair and Nails
i. Chapter 27 – Care of Patients with Skin Problems
j. Chapter 28 – Care of Patients with Burns
k. Chapter 29 – Assessment of the Respiratory System
l. Chapter 30 - Care of Patients Requiring Oxygen Therapy or Tracheostomy
m. Chapter 31 – Care of Patients with Noninfectious Upper Respiratory Problems
n. Chapter 32 – Care of Patients with Noninfectious Lower Respiratory
Problems
D. NCLEX documents
1. Acknowledgement of Receipt of NCLEX Examination Registration, 12/20/2018
2. Authorization to Test, 1/2/2019
E. NYS Registered Professional Nurse
1. License Number 763308, issued 1/18/2019
2. Registration Certificate, valid through 8/31/2024
F. Post RN License Education
1. Aspen University, Bachelor of Science in Nursing, Completed 11/30/2020
a. Transcript
b. Degree
G. Recognition received for work as a Registered Nurse
1. New York State Assembly Citation, 5/13/2022
• “Nurse Salamat Yusifu working for Morris Heights Health Center … the
leadership, tenacity, and perseverance Nurse Salamat has, so often goes,
unrecognized and unrewarded, now therefore be it; Resolved that as a duly
elected member of the State Assembly of New York, I recognize the outstanding
Nurse that is Salamat Yusifu.”
2. Certificate of Appreciation in Recognition of Dedicated Service, May 2022
2
EXHIBIT DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024
From: Beth Atwood
To: OPDPLS
Cc: Jesse Baldwin
Subject: Salamat Yusifu RN License No. 763308
Date: Monday, October 30, 2023 8:16:00 AM
Attachments: Yusifu, Salamat - INDEX OF SUPPORTING DOCUMENTATION.pdf
image001.png
2.13.2023 JBB - Hamilton w exhibits_Redacted.pdf
Yusifu, Salamat - 10.30.2023 JB - Submission letter NY OP.pdf
Dear Mr. Hamilton:
Attached please find correspondence from attorney Jesse Baldwin concerning our client, Salamat
Yusifu, RN license number 763308. 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 DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index
Preview
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024 Jesse B. Baldwin, Esq. jbaldwin@acbfirm.com October 30, 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: Salamat Eniola Yusifu RN License No. 763308 Dear Mr. Hamilton: On behalf of Salamat Yusifu, RN/BSN, we write continuance of cooperation with your office and your inquiry about our client’s education and qualifications. Nurse Yusifu has been licensed as an RN in New York State since January 18, 2019. Enclosed herewith is a jump drive with materials we have gathered to demonstrate Nurse Yusifu’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 Salamat Yusifu), 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 DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 57 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 Yusifu’s license. This nurse poses no threat to the public health imperatively requiring emergency action. (See Commissioner’s Reg. 17.9). She neither committed nor knowingly participated in any fraud. As described more fully below and in the enclosed materials, Nurse Yusifu did attend and complete a nursing education program at Palm Beach School of Nursing. The program included classroom instruction and clinical training. Nurse Yusifu passed the NCLEX. The fact that a nursing school attended by this nurse may have sold or given out fraudulent degrees to other students does not render this particular nurse a threat to the public health. We believe your office is aware of this fact, since more eight months have passed since your initial letter to Nurse Yusifu and no direct action has been taken, nor has any proceeding been commenced against her license. No misconduct or other grounds for discipline Nurse Yusifu 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 are the legal requirements for obtaining her RN license. Absent any fraud on her part, there is no basis to take her license from her. Nurse Yusifu has clearly and obviously committed no fraud. The degree she obtained from Palm Beach School of Nursing (hereinafter PBSON) was not purchased; it was earned. Prior to attending PBSON, Nurse Yusifu completed her LPN training at Best Care Training Institute in New Jersey, passed her NCLEX-PN and was licensed as an LPN in the State of New York. She also earned 42.50 credit hours, while maintaining a cumulative GPA of 3.574, as a nursing major at Hostos Community College. Documents related to her LPN are contained in Exhibit A and her transcript from Hostos Community College are contained in Exhibit B on the materials on the jump drive provided with this correspondence. Her LPN license and transcripts of previous education were included as part of her application process to PBSON. She was also required to take an entrance examination. She attended more than 30 classes, at least half of which were in person. The rest were online. She retained some of her course presentation materials, which are included at Exhibit C. Her RN education included quizzes and examinations. Her transcript evaluation form, acceptance letter, email communications with school representatives concerning a finished class, proof of payment, photographs of Nurse Yusifu at the PBSON learning center, as well as proof of travel expenses in Florida are also included at Exhibit C. Nurse Yusifu completed 80 clinical hours at a hospital in Florida, an additional 30 clinical hours at the school’s lab/stimulus class, and an additional 90 clinical hours supervised and verified by a preceptor. Prior to PBSON, she completed 610 clinical hours during her LPN training. 2 EXHIBIT DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024 Given these facts, it cannot reasonably be suggested that Nurse Yusifu participated in any fraud or made any material misrepresentations on her license application materials. Nurse Yusifu’s competence as an RN is established In addition to the education discussed above, Nurse Yusifu continued her nursing education and completed her Bachelor of Science in Nursing, Summa Cum Laude, from Aspen University in 2020. (Exhibit F) Prior to obtaining her RN, beginning in 2013, Nurse Yusifu worked as an LPN in positions involving direct patient care at Pioneer Home (2013-2015), RCM Technology (2015 – 2017) and Montefiore Family Care Center (2018-2019). Her duties included monitoring patient vital signs; maintaining cleanliness and comfort of each patient, including bathing, feeding and dressing; assisting nursing and medical staff with basic medical tasks, such as administering medication, evaluating the patient's wellbeing, reporting any needs to medical staff, changing dressings and bandages, and ensuring patients are healing properly. Since obtaining her RN license in 2019, Nurse Yusifu has worked as an RN in several positions rendering care to patients. These include the Institute for Family Health (2019-2021), Morris Heights Health Center (2021-2022) and Helping U Home Care Agency (2019-2023). She rendered direct patient care in each of these positions with duties including monitoring and coordinating the daily patient care activities of the unit; scheduling staff and patients to ensure full coverage of patient care needs at all times and to ensure effective patient services; provide triage advice and guidance to patients; administering and monitoring medications; assisting patients with activities of daily living including feeding, dressing and bathing; performing basic and advanced life support, end of life care, physical examinations, and vital signs checks; and preparing patients for bedside procedures and surgeries. In addition to her professional education and training, Nurse Yusifu’s competence has been recognized by the New York State Assembly, who presented her with a citation on May 13, 2022 for her work at Morris Heights Health Center. The citation states that “… the leadership, tenacity and perseverance Nurse Salamat has, so often goes unrecognized and unrewarded” and recognizes Salamat Yusifu not only as a competent nurse, but as an “outstanding Nurse.” Additionally, Nurse Yusifu received a Certificate of Appreciation in Recognition of Dedicated Service in May 2022. (Exhibit G) Conclusion For the reasons stated above, and based on the evidence enclosed, it is clear Salamat Yusifu lawfully obtained her nursing license has gone on to advance her training and to provide 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 DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024 To avoid misconduct charges and a plenary hearing, we are happy to discuss a way to resolve this issue and address the Department’s concerns regarding Nurse Yusifu’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 DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024 INDEX OF SUPPORTING DOCUMENTATION ON BEHALF OF SALAMAT ENIOLA YUSIFU, RN A. Licensed Practical Nurse 1. New York State License No. 316868, issued 10/28/2013 2. New York State LPN Registration Certificate, valid through 8/31/2022 3. Best Care Training Institute, LPN Program a. Transcript b. Diploma B. Previous Education 1. Hostos County Community College – nursing major a. Transcript C. Palm Beach School of Nursing, Associates of Science of Nursing 1. Documents specific to Salamat Yusifu a. Official Transcript b. Associate of Science in Nursing, Degree c. Transcript Evaluation Form d. Acceptance letter e. Receipts f. Email message, 5.21.2018, concerning finished class g. Learning Center photographs h. Evidence of travel expenses in Florida i. Car Rental, March 31, 2018 2. General Orientation Documents a. General Orientation Information b. Application Information c. RN Program Breakdown By Course d. RN Booklist e. Clinical Location Disclosure f. RN Checklist g. Enrollment Agreement h. Physical Assessment Form i. Hep B and Flu Declination 3. Course Materials a. Chapter 16 – Care of Preoperative Patients b. Chapter 17 - Care of Intraoperative Patients 1 EXHIBIT DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024 c. Chapter 18 – Care of Postoperative Patients d. Chapter 22 – Care of patients with Immune Function Excess: Hypersensitivity (Allergy) and Autoimmunity e. Chapter 23 – Cancer Development f. Chapter 24 – Care of Patients with Cancer g. Chapter 25 – Care of Patients with Infection h. Chapter 26 – Assessment of the Skin, Hair and Nails i. Chapter 27 – Care of Patients with Skin Problems j. Chapter 28 – Care of Patients with Burns k. Chapter 29 – Assessment of the Respiratory System l. Chapter 30 - Care of Patients Requiring Oxygen Therapy or Tracheostomy m. Chapter 31 – Care of Patients with Noninfectious Upper Respiratory Problems n. Chapter 32 – Care of Patients with Noninfectious Lower Respiratory Problems D. NCLEX documents 1. Acknowledgement of Receipt of NCLEX Examination Registration, 12/20/2018 2. Authorization to Test, 1/2/2019 E. NYS Registered Professional Nurse 1. License Number 763308, issued 1/18/2019 2. Registration Certificate, valid through 8/31/2024 F. Post RN License Education 1. Aspen University, Bachelor of Science in Nursing, Completed 11/30/2020 a. Transcript b. Degree G. Recognition received for work as a Registered Nurse 1. New York State Assembly Citation, 5/13/2022 • “Nurse Salamat Yusifu working for Morris Heights Health Center … the leadership, tenacity, and perseverance Nurse Salamat has, so often goes, unrecognized and unrewarded, now therefore be it; Resolved that as a duly elected member of the State Assembly of New York, I recognize the outstanding Nurse that is Salamat Yusifu.” 2. Certificate of Appreciation in Recognition of Dedicated Service, May 2022 2 EXHIBIT DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 02/21/2024 From: Beth Atwood To: OPDPLS Cc: Jesse Baldwin Subject: Salamat Yusifu RN License No. 763308 Date: Monday, October 30, 2023 8:16:00 AM Attachments: Yusifu, Salamat - INDEX OF SUPPORTING DOCUMENTATION.pdf image001.png 2.13.2023 JBB - Hamilton w exhibits_Redacted.pdf Yusifu, Salamat - 10.30.2023 JB - Submission letter NY OP.pdf Dear Mr. Hamilton: Attached please find correspondence from attorney Jesse Baldwin concerning our client, Salamat Yusifu, RN license number 763308. 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 DDD - Yusifu, Salamat - 10.30.2023 Baldwin - NYSED with index