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. 25 RECEIVED NYSCEF: 02/21/2024
Jesse B. Baldwin, Esq.
jbaldwin@acbfirm.com
November 8, 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: Celestine Chi Aririguzoh
RN License No. 769319
Dear Mr. Hamilton:
On behalf of Celestine Chi Aririguzoh, RN we write continuance of cooperation with your office
and your inquiry about our client’s education and qualifications. Nurse Aririguzoh received his
license as an RN in New York State on May 10, 2019. Enclosed herewith is a jump drive with
materials we have gathered to demonstrate Nurse Aririguzoh’s qualifications and competence.
Also enclosed is an index of those materials, to help with your review, attached as Exhibit 1.
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. We wrote you
a subsequent letter on April 28, 2023, concerning the circumstances of Nurse Aririguzoh’s
graduation date predating the investigation date, which is attached as Exhibit 2. 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.
Nurse Aririguzoh’s graduation date predates the
Operation Nightingale investigation period
We believe your correspondence was sent to Mr. Aririguzoh in error, and the Nightingale
investigation that resulted in your letter does not apply to him because he completed his RN
education before the timeframe at issue. Mr. Aririguzoh completed his RN education program at
5680 Main Street | Buffalo, New York 14221
716-475-9533 | www.acbfirm.com
EXHIBIT X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024
Med Life Institute on February 29, 2016. The Interim Update posted on your website indicates
the timeframe involved for Med Life Institute WBP LLC begins in October 2016, more than seven
months after Mr. Aririguzoh graduated. Copies of his transcript and degree are provided at Exhibit
C in the materials contained on the jump drive provided with this letter. As the Department is
aware, Med Life Institute has been closed due to Operation Nightingale. Despite his best efforts,
Nurse Aririguzoh is unable to order an official transcript from Med Life Institute to have it directly
submitted to the Department at this time. As stated above, however, Nurse Aririguzoh retained a
copy of the transcript which is included on the jump drive at Exhibit C.
No grounds for summary suspension
As briefly described in our prior letter, there are no grounds for a summary suspension of Nurse
Aririguzoh’s license. This nurse poses no threat to the public health imperatively requiring
emergency action. (See Commissioner’s Reg. 17.9). He neither committed nor knowingly
participated in any fraud. As described more fully below and in the enclosed materials, Nurse
Aririguzoh did attend and complete a nursing education program at Med Life Institute School of
Nursing. The program included classroom instruction and clinical training. Nurse Aririguzoh
passed the NCLEX. The fact that a nursing school attended by this nurse may have sold or given
out fraudulent degrees to students other than Nurse Aririguzoh does not render this particular nurse
a threat to the public health. We believe your office is aware of this fact, since more than nine
months have passed since your initial letter to Nurse Aririguzoh and no direct action has been
taken, nor has any proceeding been commenced against his license.
No misconduct or other grounds for discipline
Nurse Aririguzoh is entitled to retain his RN license. He obtained this license in full compliance
with applicable law. He completed the educational requirement for licensure in accordance with
Commissioner’s Reg. 64.1(a)(2) by completing a program in nursing approved by the licensing
authority of Florida for practice as a Registered Nurse. Nurse Aririguzoh was authorized to sit for
the NCLEX and passed the exam. These were the legal requirements for obtaining his RN license.
Absent any fraud on his part, there is no basis to take his license from him.
Although Commissioner’s Reg. 64.1(a)(2) has since been amended to change the requirements
and allow the Department to determine another State’s nursing program to be unsatisfactory does
not change the fact that Nurse Aririguzoh satisfied the regulatory requirements in place at the time,
which was long before April 18, 2023, the effective date of the regulatory change approved by the
Regents in the April 2023 meeting. Since Nurse Aririguzoh already had a lifetime right to his
license obtained before this change, the regulatory change cannot be applied to him retroactively.
Nurse Aririguzoh has clearly and obviously committed no fraud. The degree he obtained from
Med Life Institute School of Nursing (hereinafter “Med Life Institute”) was not purchased; it was
earned. Prior to attending Med Life Institute, Nurse Aririguzoh completed a practical nursing
program through his high school, passed the NCLEX-PN, and received his license as a Practical
Nurse in Pennsylvania on October 31, 2013. Documents related to his LPN license are contained
2
EXHIBIT X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024
at Exhibit A on the jump drive included with this letter. Thereafter, he was enrolled in the
Professional Nursing program at Jersey College. (Exhibit B)
His transcripts, LPN license, entrance examination, telephone interview, and application fee were
included as part of his admission process to Med Life Institute. Med Life Institute granted him
transfer credits based on his prior education and clinical training. He attended numerous classes,
all of which were in person. He travelled to Florida several times, each trip being 6 days long, for
the purpose of attending classes and clinical training. His RN education included homework,
quizzes, and examinations. Included in Exhibit C are his transcript evaluation form and evidence
of travel expenses incurred in Florida.
Nurse Aririguzoh completed at least 700 clinical hours, both through those verified with preceptors
at his place of employment and in Florida. Clinical sites in Florida included Tender Care Center,
Lakeside Medical Center, South County Mental Health Center, Hollywood Birth Center, and
Seaview Rehab & Nursing Center. Prior to attending Med Life Institute, he completed 255 clinical
hours during his LPN training, as well as approximately 300 clinical hours while at Jersey College.
His clinical rotations while enrolled at Jersey College included Medical Surgical, Geriatric (at
Greenwood House), Psychiatric (at Trenton Psychiatric Hospital), Maternal-Newborn, and
Pediatrics (both at Capital Health Hospital).
Given these facts, it cannot reasonably be suggested that Nurse Aririguzoh participated in any
fraud or made any material misrepresentations on his license application materials.
Nurse Aririguzoh’s competence as an RN is establihed
Prior to earning his RN, for several years Nurse Aririguzoh worked as an LPN providing direct
patient care in several positions including Aveanna Health Care (2014 – 2021); Maxim Health
Services (2016 – 2018); and Providence Nursing Home (2018 – 2022). In these various positions,
his job duties included assisting with daily patient functions; medication administration; wound
care; and observation and monitoring of patients and reporting acute conditions to medical team.
Since earning his RN, Nurse Arirguzoh has worked as an RN with All American Health Care
(8/2020 – 12/2020); Aveanna Health Services (1/2021 – 10/2021) and Office of Addiction Services
and Support (10/2022 – 5/2022). In each of these positions, he has provided direct patient care
with job duties that have included receiving and verifying patient medication orders; administering
medications; verifying lab orders; patient admissions and discharges; organizing groups according
to timetable provided by nurse administrator; transferring patients to hospitals during emergency
health situations, and organizing patient follow up visits.
Conclusion
For the reasons stated above, and based on the evidence enclosed, it is clear Nurse Aririguzoh
lawfully obtained his nursing license, and has gone on to provide professional nursing services.
3
EXHIBIT X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024
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 would be happy to discuss a way to resolve
this issue and address the Department’s concerns regarding Nurse Aririguzoh’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 X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024
INDEX OF SUPPORTING DOCUMENTATION
ON BEHALF OF
CELESTINE CHI ARIRIGUZOH, RN
School Attended: Med-Life Institute
Dates of Attendance: 6/29/2015 – 2/29/2016
DATES OF ATTENDANCE PREDATE INVESTIGATION DATES FROM STATE OF NY.
A. Licensed Practical Nurse
1. Pennsylvania License Number PN296135, valid through 6/30/2024
B. Previous Education
1. Jersey College
a. Transcript
b. Letter confirming completion of clinical hours
C. Med-Life Institute, Associates of Science of Nursing
1. Documents specific to Celestine Chi Aririguzoh
a. Official Transcript, dates attended: 6/29/2015 – 2/29/2016
b. Associate of Science in Nursing, Degree issued 2/29/2016
c. Transcript Evaluation Form
d. Evidence of travel expenses in Florida
a. Flight confirmations
2. General Documents
a. Entrance requirements
b. Tuition & Fees
c. Comprehensive RN Review
D. NYS Registered Professional Nurse
1. License Number 769319 issued 5/10/2019
2. Registration Certificate, valid through 4/30/2022 and 10/31/2024
3. Nursys Nurse License Verification for Endorsement
EXHIBIT X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024
From: Beth Atwood
To: OPDPLS
Cc: Jesse Baldwin
Subject: Celestine Chi Aririguzoh, RN License No. 769319
Date: Wednesday, November 8, 2023 11:21:00 AM
Attachments: Aririguzoh, Celestine Chi - 11.8.2023 - Submission ltr to NY OP.pdf
image001.png
Exhibit 1 - prior submission ltr.pdf
Exhibit 2 - INDEX OF SUPPORTING DOCUMENTATION - Aririguzoh, Celestine Chi.pdf
Dear Mr. Hamilton:
Attached please find correspondence from attorney Jesse Baldwin concerning our client, Celestine
Chi Aririguzoh, RN License No. 769319. Also attached is our prior correspondence of February 14,
2023 and April 8, 2023 (Exhibit 1) and an index of supporting documentation (Exhibit 2).
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 X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index
Preview
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024 Jesse B. Baldwin, Esq. jbaldwin@acbfirm.com November 8, 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: Celestine Chi Aririguzoh RN License No. 769319 Dear Mr. Hamilton: On behalf of Celestine Chi Aririguzoh, RN we write continuance of cooperation with your office and your inquiry about our client’s education and qualifications. Nurse Aririguzoh received his license as an RN in New York State on May 10, 2019. Enclosed herewith is a jump drive with materials we have gathered to demonstrate Nurse Aririguzoh’s qualifications and competence. Also enclosed is an index of those materials, to help with your review, attached as Exhibit 1. 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. We wrote you a subsequent letter on April 28, 2023, concerning the circumstances of Nurse Aririguzoh’s graduation date predating the investigation date, which is attached as Exhibit 2. 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. Nurse Aririguzoh’s graduation date predates the Operation Nightingale investigation period We believe your correspondence was sent to Mr. Aririguzoh in error, and the Nightingale investigation that resulted in your letter does not apply to him because he completed his RN education before the timeframe at issue. Mr. Aririguzoh completed his RN education program at 5680 Main Street | Buffalo, New York 14221 716-475-9533 | www.acbfirm.com EXHIBIT X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024 Med Life Institute on February 29, 2016. The Interim Update posted on your website indicates the timeframe involved for Med Life Institute WBP LLC begins in October 2016, more than seven months after Mr. Aririguzoh graduated. Copies of his transcript and degree are provided at Exhibit C in the materials contained on the jump drive provided with this letter. As the Department is aware, Med Life Institute has been closed due to Operation Nightingale. Despite his best efforts, Nurse Aririguzoh is unable to order an official transcript from Med Life Institute to have it directly submitted to the Department at this time. As stated above, however, Nurse Aririguzoh retained a copy of the transcript which is included on the jump drive at Exhibit C. No grounds for summary suspension As briefly described in our prior letter, there are no grounds for a summary suspension of Nurse Aririguzoh’s license. This nurse poses no threat to the public health imperatively requiring emergency action. (See Commissioner’s Reg. 17.9). He neither committed nor knowingly participated in any fraud. As described more fully below and in the enclosed materials, Nurse Aririguzoh did attend and complete a nursing education program at Med Life Institute School of Nursing. The program included classroom instruction and clinical training. Nurse Aririguzoh passed the NCLEX. The fact that a nursing school attended by this nurse may have sold or given out fraudulent degrees to students other than Nurse Aririguzoh does not render this particular nurse a threat to the public health. We believe your office is aware of this fact, since more than nine months have passed since your initial letter to Nurse Aririguzoh and no direct action has been taken, nor has any proceeding been commenced against his license. No misconduct or other grounds for discipline Nurse Aririguzoh is entitled to retain his RN license. He obtained this license in full compliance with applicable law. He completed the educational requirement for licensure in accordance with Commissioner’s Reg. 64.1(a)(2) by completing a program in nursing approved by the licensing authority of Florida for practice as a Registered Nurse. Nurse Aririguzoh was authorized to sit for the NCLEX and passed the exam. These were the legal requirements for obtaining his RN license. Absent any fraud on his part, there is no basis to take his license from him. Although Commissioner’s Reg. 64.1(a)(2) has since been amended to change the requirements and allow the Department to determine another State’s nursing program to be unsatisfactory does not change the fact that Nurse Aririguzoh satisfied the regulatory requirements in place at the time, which was long before April 18, 2023, the effective date of the regulatory change approved by the Regents in the April 2023 meeting. Since Nurse Aririguzoh already had a lifetime right to his license obtained before this change, the regulatory change cannot be applied to him retroactively. Nurse Aririguzoh has clearly and obviously committed no fraud. The degree he obtained from Med Life Institute School of Nursing (hereinafter “Med Life Institute”) was not purchased; it was earned. Prior to attending Med Life Institute, Nurse Aririguzoh completed a practical nursing program through his high school, passed the NCLEX-PN, and received his license as a Practical Nurse in Pennsylvania on October 31, 2013. Documents related to his LPN license are contained 2 EXHIBIT X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024 at Exhibit A on the jump drive included with this letter. Thereafter, he was enrolled in the Professional Nursing program at Jersey College. (Exhibit B) His transcripts, LPN license, entrance examination, telephone interview, and application fee were included as part of his admission process to Med Life Institute. Med Life Institute granted him transfer credits based on his prior education and clinical training. He attended numerous classes, all of which were in person. He travelled to Florida several times, each trip being 6 days long, for the purpose of attending classes and clinical training. His RN education included homework, quizzes, and examinations. Included in Exhibit C are his transcript evaluation form and evidence of travel expenses incurred in Florida. Nurse Aririguzoh completed at least 700 clinical hours, both through those verified with preceptors at his place of employment and in Florida. Clinical sites in Florida included Tender Care Center, Lakeside Medical Center, South County Mental Health Center, Hollywood Birth Center, and Seaview Rehab & Nursing Center. Prior to attending Med Life Institute, he completed 255 clinical hours during his LPN training, as well as approximately 300 clinical hours while at Jersey College. His clinical rotations while enrolled at Jersey College included Medical Surgical, Geriatric (at Greenwood House), Psychiatric (at Trenton Psychiatric Hospital), Maternal-Newborn, and Pediatrics (both at Capital Health Hospital). Given these facts, it cannot reasonably be suggested that Nurse Aririguzoh participated in any fraud or made any material misrepresentations on his license application materials. Nurse Aririguzoh’s competence as an RN is establihed Prior to earning his RN, for several years Nurse Aririguzoh worked as an LPN providing direct patient care in several positions including Aveanna Health Care (2014 – 2021); Maxim Health Services (2016 – 2018); and Providence Nursing Home (2018 – 2022). In these various positions, his job duties included assisting with daily patient functions; medication administration; wound care; and observation and monitoring of patients and reporting acute conditions to medical team. Since earning his RN, Nurse Arirguzoh has worked as an RN with All American Health Care (8/2020 – 12/2020); Aveanna Health Services (1/2021 – 10/2021) and Office of Addiction Services and Support (10/2022 – 5/2022). In each of these positions, he has provided direct patient care with job duties that have included receiving and verifying patient medication orders; administering medications; verifying lab orders; patient admissions and discharges; organizing groups according to timetable provided by nurse administrator; transferring patients to hospitals during emergency health situations, and organizing patient follow up visits. Conclusion For the reasons stated above, and based on the evidence enclosed, it is clear Nurse Aririguzoh lawfully obtained his nursing license, and has gone on to provide professional nursing services. 3 EXHIBIT X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024 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 would be happy to discuss a way to resolve this issue and address the Department’s concerns regarding Nurse Aririguzoh’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 X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024 INDEX OF SUPPORTING DOCUMENTATION ON BEHALF OF CELESTINE CHI ARIRIGUZOH, RN School Attended: Med-Life Institute Dates of Attendance: 6/29/2015 – 2/29/2016 DATES OF ATTENDANCE PREDATE INVESTIGATION DATES FROM STATE OF NY. A. Licensed Practical Nurse 1. Pennsylvania License Number PN296135, valid through 6/30/2024 B. Previous Education 1. Jersey College a. Transcript b. Letter confirming completion of clinical hours C. Med-Life Institute, Associates of Science of Nursing 1. Documents specific to Celestine Chi Aririguzoh a. Official Transcript, dates attended: 6/29/2015 – 2/29/2016 b. Associate of Science in Nursing, Degree issued 2/29/2016 c. Transcript Evaluation Form d. Evidence of travel expenses in Florida a. Flight confirmations 2. General Documents a. Entrance requirements b. Tuition & Fees c. Comprehensive RN Review D. NYS Registered Professional Nurse 1. License Number 769319 issued 5/10/2019 2. Registration Certificate, valid through 4/30/2022 and 10/31/2024 3. Nursys Nurse License Verification for Endorsement EXHIBIT X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 02/21/2024 From: Beth Atwood To: OPDPLS Cc: Jesse Baldwin Subject: Celestine Chi Aririguzoh, RN License No. 769319 Date: Wednesday, November 8, 2023 11:21:00 AM Attachments: Aririguzoh, Celestine Chi - 11.8.2023 - Submission ltr to NY OP.pdf image001.png Exhibit 1 - prior submission ltr.pdf Exhibit 2 - INDEX OF SUPPORTING DOCUMENTATION - Aririguzoh, Celestine Chi.pdf Dear Mr. Hamilton: Attached please find correspondence from attorney Jesse Baldwin concerning our client, Celestine Chi Aririguzoh, RN License No. 769319. Also attached is our prior correspondence of February 14, 2023 and April 8, 2023 (Exhibit 1) and an index of supporting documentation (Exhibit 2). 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 X - Aririguzoh, C - 11.8.2023 Baldwin - NYSED with index