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. 52 RECEIVED NYSCEF: 02/21/2024
Jesse B. Baldwin, Esq.
jbaldwin@acbfirm.com
April 21, 2023
VIA EMAIL: OPDPLS@nysed.gov and
REGULAR MAIL
David Hamilton, LMSW
Assistant Commissioner, OP
State Education Department
DPLS Director’s Office
89 Washington Avenue
Albany, New York 12234-1000
RE: GELIN, Louise Nina
RN License No. 771180-01
LPN License No. 327566-01
Dear Mr. Hamilton:
On behalf of Louise Nina Gelin, LPN, RN, BSN we write continuance of cooperation with your
office and your inquiry about our client’s education and qualifications. Enclosed herewith is a
jump drive with materials we have gathered to demonstrate Nurse Gelin’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 Nurse Gelin),
is enclosed, and 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 YY - Gelin, L - 4.21.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 52 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
Gelin’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 Gelin did attend
and complete nursing education programs at Azure College School of Nursing (Bachelor of
Science) and Palm Beach School of Nursing (Associate Degree). The programs included
classroom instruction and clinical training. Nurse Gelin passed the NCLEX. The fact that a
nursing school attended by this nurse may have also sold or given our 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 than ten (10) weeks have passed since your initial letter to Nurse
Gelin and no direct action has been taken, nor has any proceeding been commenced against her
license.
No misconduct or other grounds for discipline
Nurse Gelin 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 programs 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 Gelin has clearly and obviously committed no fraud. The degree she obtained from Palm
Beach School of Nursing was not purchased; it was earned. Nurse Gelin was required to pass an
entrance and an exit examination to complete the program. She attended in person classes twice
per week in Baldwin, New York. She retained some of her course presentation materials, which
are included in the materials on the jump drive included with this letter. Her RN education
included quizzes and examinations conducted on a weekly basis, as well as simulations and clinical
hours. Nurse Gelin traveled to Florida to attend a formal graduation ceremony. Photographs of the
ceremony are included with the accompanying submission.
Given these facts, it cannot reasonably be suggested that Nurse Gelin participated in any fraud or
made any material misrepresentations on her license application materials.
Nurse Gelin’s competence as an RN/LPN is established
In addition to the education discussed above, Nurse Gelin obtained her Bachelors of Science in
Nursing, summa cum laude, from Azure College School of Nursing in 2021.
Prior to obtaining her RN license, Nurse Gelin worked as an LPN in several positions involving
patient care, including: Sono Bello, where she performed perioperative services, IV insertions,
blood work, and medication administration; South Nassau Dermatology, where she performed
services including medication administration, procedure preparation, and monitoring vital signs;
and RMA IVF, where she cared for recovering post-operative patients, prepared patients for
EXHIBIT YY - Gelin, L - 4.21.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/21/2024
fertility treatments, monitoring vital signs, performed blood draws, and performed IV insertions.
Nurse Gelin completed at least 460 clinical hours prior to obtaining her RN license.
Since obtaining her RN license in 2019, Nurse Gelin has worked in several positions as an RN
rendering care to patients. These include a position as an RN at RMA IVF from March 2019-
September 2019, an emergency psychiatric nurse at Nassau University Medical Center from
September 2019-November 2021, and as a perioperative registered nurse at Mercy Medical Center
from December 2021 to the present. She rendered direct patient care in each of these positions. In
addition, she has devoted over 100 hours to continuing education trainings and certifications to
enhance her knowledge and patient care. Documentation regarding these hours accompanies this
submission.
Accompanying this submission are letters from several of Nurse Gelin’s colleagues. These
colleagues describe an effective, hardworking, inquisitive, and dedicated RN.
Conclusion
For the reasons stated above, and based on the evidence enclosed, it is clear Nurse Gelin lawfully
obtained her nursing licenses and has gone on to advance her education and 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.
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 Gelin’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
EXHIBIT YY - Gelin, L - 4.21.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/21/2024
INDEX OF SUPPORTING DOCUMENTATION
ON BEHALF OF
LOUISE GELIN, RN
School Attended: Palm Beach School of Nursing
Dates of Attendance: 1/4/2016 – 9/29/2017
A. Licensed Practical Nurse
1. License Number 327566
2. Registration Certificate, valid through 8/31/2025
3. Vocational Education & Extension Board
a. Transcript, Practical Nursing
b. Certificate of Completion
B. Palm Beach School of Nursing, Associates of Science of Nursing
1. Documents specific to Louise Gelin
a. Official Transcript, dates attended: 1/4/2016 – 9/29/2017
b. Associate of Science in Nursing, Degree
c. Photos
d. Evidence of travel expenses in Florida
i. Jet Blue Travel Documents
2. General Admission and Orientation Documents
a. Brochure – Nursing Associate of Science
b. Entrance Packet
c. Nursing – Associate of Science Course Description
d. Entrance Exam Subjects
e. Admissions profile form
f. Welcome letter describing SHOMA – popular custom rooming arrangement
g. DocuNow drug testing
3. General Documents
a. Promotional Flyer for Palm Beach School of Nursing - “Open Enrollment! No
Waiting Lists!”
b. “NY Board of Nursing – Things you need”
4. Course Materials
a. Course Syllabuses
i. HSC 104, Pathophysiology
ii. Nur 100, LPN to RN Transition
iii. Nur 101, Introduction to Health Care
iv. Nur 103, Pharmacology
v. Nur 104, Critical Thinking and the Nursing Process
vi. Nur 201, Adult Nursing I
vii. Nur 203, Psychiatric and Mental Health Nursing
1
EXHIBIT YY - Gelin, L - 4.21.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/21/2024
viii. Nur 205, Maternal Child Nursing
ix. Nur 207, Pediatric Nursing
x. Nur 301, Adult Nursing II
xi. Nur 402, Professional Nursing Leadership
xii. Internet Resources to Improve Learning, Reading, Studying & Test
Taking
b. Select Course Chapters
i. Wolters Kluwer, Chapter 22 – Nurse Leader, Manager & Care
Coordinator
ii. Wolters Kluwer, Chapter 23 - Asepsis and Infection Control
iii. Wolters Kluwer, Chapter 26 – Safety, Security, and Emergency
Preparedness
iv. Wolters Kluwer, Chapter 31, Skin Integrity and Wound Care
v. Mosby, Chapter 23 – Postpartum Complications
vi. Mosby, Chapter 24 – Physiologic Adaptations of the Newborn
c. Clinical Forms
i. Sample – Clinical/Experiential Learning Evaluation forms
1. Letter from Palm Beach School of Nursing
a. Palm Beach School of Nursing sincerely thanks you for
agreeing to supervise our ASN candidate. The student
must be supervised and evaluated by a Registered
Nurse who has a Bachelor’s of Science degree or
higher in order to meet institutional standards. … There
is a sample document provided to demonstrate how the
Preceptor is to evaluate our student.
ii. Sample - PBSON care plan
d. Psychiatry – Pharmacology – Psychiatric condition preferred drugs
e. 2017 Holiday Schedule
f. Exit Exam – HESI Account
C. NCLEX documents
1. Authorization to Test, test validity 26 June 2018 – 24 September 2018
D. NYS Registered Professional Nurse
1. License Number 711180
2. Registration Certificate, valid through 8/31/2024
E. Post RN License Education
1. Azure College, Bachelor of Science in Nursing, Completed 10/28/2021
a. Transcript
b. Degree
c. Evidence of Capstone Project
2
EXHIBIT YY - Gelin, L - 4.21.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/21/2024
2. Periop 101: A Core Curriculum
a. Certificate of Completion, AORN
i. Contact Hours: 39.80
b. Certificate of Completion, Perioperative Nursing Data Set
i. Contact Hours: 1.70
c. AORN PERIOP 101: A Core Curriculum Didactic OR Course
F. Letters of Support
1. Letter from Tracy Smith, DNP MSN FNP-BC
• As the NP for the team, it is my primary responsibility to ensure that all the
clinical safety measures are in place for patients prior to their surgical
procedures. Louise is a team member in the capacity of a peri-op nurse. She
has been an effective clinician in conducting the pertinent pre-operative
assessments, verifications, and documentation. She is meticulous in ensuring
that patients have met all the clinical criteria and adds immeasurable value as
a member of the Operating Room team. Miss Gelin possesses great
fundamental nursing, critical thinking and clinical skills.
2. Letter from Antoinette Baleba-Lekane, BS, BSN, MSN, ACNP, CRNA, DNP
• I was initially impressed by her ability to quickly learn and adapt to the fast
paced and ever changing environment that is the operating room. She was
able to work throughout different roles, first as a trainee, then a mentor to
other nurses or members of the multidisciplinary team.
• Her ability to work well in a team setting makes her a valuable member of the
team.
• Louise gets along well with her coworkers and the multidisciplinary team that
gravitate in the OR. She is hardworking, efficient, reliable and dedicated to
the profession and the care of her patients for whom she is a formidable
advocate.
3. Letter from Jacob D. Spencer BSN, RN, DipACLM
• I’ve had the pleasure of not only training Ms. Gelin, but also working beside
and watching her grow in her competence as a surgical nurse. She has
always displayed professionalism, perseverance, determination, and
resilience. This has made a world of difference in her progression as an OR
nurse.
3
EXHIBIT YY - Gelin, L - 4.21.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 02/21/2024
From: Beth Atwood
To: OPDPLS
Cc: Jesse Baldwin; Kara Addelman; Lou RN
Subject: Louise Gelin RN License No. 771180-01
Date: Friday, April 21, 2023 6:58:00 AM
Attachments: 4.21.2023 Gelin Louise - Ltr to NYS Education Dept.pdf
image001.png
Dear Mr. Hamilton –
This firm represents Louise Gelin in connection with her professional license as a registered nurse.
Please see the attached correspondence from attorney Jesse Baldwin, a hard copy of which will be
sent via regular mail with a jump drive with materials we have gathered to demonstrate Nurse
Gelin’s qualifications and competence
Please notify us if you need anything further.
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 YY - Gelin, L - 4.21.2023 Baldwin - NYSED with index