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. 21 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: Charity Akakpo
RN License No. 760915
Dear Mr. Hamilton:
On behalf of Charity Akakpo, RN/BSN we write continuance of cooperation with your office and
your inquiry about our client’s education and qualifications. Nurse Akakpo received her license
as an RN in New York State on November 9, 2018, five years ago this week. Enclosed herewith
is a jump drive with materials we have gathered to demonstrate Nurse Akakpo’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
subsequent letters on March 23, 2023 and April 20, 2023 concerning the circumstances of Nurse
Akakpo’s graduation date predating the investigation date, which are 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.
5680 Main Street | Buffalo, New York 14221
716-475-9533 | www.acbfirm.com
EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024
Nurse Akakpo’s graduation date predates the
Operation Nightingale investigation period
We believe your correspondence was sent to Ms. Akakpo in error, and the Nightingale
investigation that resulted in your letter to Nurse Akakpo does not apply to her because she
completed her RN education before the timeframe at issue. Ms. Akakpo completed her RN
education program at Med Life Institute on June 19, 2015. The Interim Update posted on your
website indicates the timeframe involved for Med Life Institute WBP LLC begins in October 2016,
more than one year after Ms. Akakpo graduated. Copies of her 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
her best efforts, Nurse Akakpo 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, she retained
a copy of her 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
Akakpo’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
Akakpo did attend and complete a nursing education program at Med Life Institute School of
Nursing. The program included classroom instruction and clinical training. Nurse Akakpo passed
the NCLEX. The fact that a nursing school attended by this nurse may have sold or given our
fraudulent degrees to students other than Nurse Akakpo does not render this particular nurse a
threat to the public health. We believe your office is aware of this fact, because more than nine
months have passed since your initial letter to Nurse Akakpo and no direct action has been taken,
nor has any proceeding been commenced against her license.
No misconduct or other grounds for discipline
Nurse Akakpo 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. 64.1(a)(2) by completing a program in nursing approved by the licensing
authority of Florida for practice as a Registered Nurse. Nurse Akakpo was authorized to sit for
the NCLEX and passed the exam. These were the legal requirements for obtaining her RN license.
Absent any fraud on her part, there is no basis to take her license from her.
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 Akakpo 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 Akakpo already had a lifetime right to her license
obtained before this change, the regulatory change cannot be applied to her retroactively.
2
EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024
Nurse Akakpo has clearly and obviously committed no fraud. The degree she 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 Akakpo completed a practical nursing program
at American Health Care Inc., passed the NCLEX-PN, received her New Jersey license as a
Practical Nurse and was endorsed in the State of New York as of October 4, 2018. Documents
related to her LPN license and training are contained at Exhibit A on the jump drive included with
this letter. Thereafter, she was enrolled in the Professional Nursing program at Jersey College.
(Exhibit B)
Her transcripts, LPN license, entrance examination and application fee were included as part of
her admission process to Med Life Institute. Med Life Institute granted her transfer credits based
on her prior education and clinical training. Nurse Akakpo attended numerous classes, all of which
were in person. She travelled to Florida ten (10) times, each trip being 6 days long, for the purpose
of attending classes and clinical training. Her RN education included homework, quizzes and
examinations. Included in Exhibit C.1-6 is evidence confirming her enrollment, documentation of
clinical hours, as well as proof of payment of the background check and travel expenses incurred
in Florida. Nurse Akakpo kept some of her course materials from Med-Life Institute including the
Course Syllabus/Outline for the RN Program, ASN Curriculum, various Course Syllabuses,
Certificate of accreditation of Med-Life Institute with confirmation of status from the Florida
Commission for Independent Education and the Externship Affiliation Agreement. (Exhibit C.7-
11) The ASN Curriculum (Exhibit C.8) includes a chart of the clinical facility, location, clinical
services utilized, clinical hours and lab/simulation.
Nurse Akakpo completed 945 clinical hours in Florida. Clinical sites included Tender Care Center,
Lakeside Medical Center, South County Mental Health Center, Hollywood Birth Center, and
Seaview Rehab & Nursing Center. The ASN Curriculum (Exhibit C.8) includes a chart of the
clinical facility, location, clinical services utilized, clinical hours and lab/simulation. Prior to
attending Med Life Institute, she completed over 900 clinical hours during her LPN training and
clinical hours on maternity, pediatric and psychiatric nursing while enrolled at Jersey College.
(Exhibits A.3 and B)
Given these facts, it cannot reasonably be suggested that Nurse Akakpo participated in any fraud
or made any material misrepresentations on her license application materials.
Nurse Akakpo’s competence as an RN is established
In addition to the education previously discussed, Nurse Akakpo continued her nursing education
and earned her Bachelor of Science in Nursing, magna cum laude, from Chamberlin University in
2019, where she was required to complete a Capstone Project. (Exhibit F.1) She has completed
various continuing education courses through her employment as an RN. (Exhibit F.2)
Prior to earning her RN, for several years Nurse Akakpo worked as an LPN providing direct patient
care at Complete Care at Laurelton (12/2019 – 4/2022); (Wendel Garden & Rehab Center (2013-
2019) and Care One at East Brunswick (2007-2013). In these various positions, her job duties
3
EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024
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 her RN, in May 2020, Nurse Akakpo transitioned to a staff nurse (RN position) with
Complete Care at Laurelton. She has worked as an RN nurse supervisor at Staten Island Care
Center. Her duties included assessing, observing, communicating with patients, administering
medications and treatments including wound care, foley catheter insertion/care, tracheostomy care,
colostomy care, gastrostomy-tube care, and IV insertions. Nurse Akakpo worked as a Staff Nurse
– Behavioral with Richmond University Medical Center where her job duties included taking an
active role in direct assessment and care; practicing crisis intervention; formulating individualized
nursing care plans utilizing the nursing process; and assessing each resident daily and
implementing a change in the course of action as needed.
Nurse Akakpo’s colleagues and supervisors describe Nurse Akakpo as an “exemplary nurse” who
“has demonstrated competency in all areas of nursing required our various populations.” She is
described as composed under pressure, goes above and beyond to “make sure patients are as
comfortable as possible.” She is described as loyal, possessing leadership and organizational skills
in managing both clinical and non-clinical issues. Nurse Akakpo has also been described as being
a great help in preparing the facility for State review and having “worked through the toughest of
time.” (Exhibit G).
Conclusion
For the reasons stated above, and based on the evidence enclosed, it is clear Nurse Akakpo 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.
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 Akakpo’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 T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024
INDEX OF SUPPORTING DOCUMENTATION
ON BEHALF OF
CHARITY AKAPO, RN
School Attended: Med-Life Institute
Dates of Attendance: 6/19/2014 – 6/19/2015
A. Licensed Practical Nurse
1. State of New Jersey LPN License, registration valid through 5/31/2023
2. Endorsed in New York, October 4, 2018
3. American Health Care Inc.
a. Transcript
B. Previous Education
1. Jersey College
a. Transcript
b. Letter from Jersey College confirming completion of practicum courses
C. Med Life Institute School of Nursing
1. Transcript, dates attended: 6/19/2014 – 6/19/2015
2. Associates of Science of Nursing, Degree, dated 6/19/2015
3. Confirmation of Enrollment and Tuition, 2/23/2015
4. DocuNow receipt for background check and drug test
5. Clinical Hours documentation
a. Letter from Med-Life confirming acceptance of students at facility
b. Clinical/Experiential Learning Evaluation form, Tallwoods Care Center,
Bayville, NY, 40 hours, 6/8 – 6/12/2015
6. Evidence of travel expenses
a. Receipts
b. Avis Car Rental Agreement
c. National Car Rental Agreement
d. Comfort Inn & Suites, Room reservations
e. Conference and Lodging Center, reservation confirmation
f. Bank records
7. Med-Life Institute Course Syllabus/Outline for RN Program 2014-2015
8. Med-Life Institute ASN Curriculum – Total Courses and Credits Earned
9. Course Syllabus 2015
a. Fundamentals of Nursing, NUR 201
1
EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024
b. Maternal Newborn Nursing, NUR 205
c. Pediatric Nursing, NUR 207
10. Med-Life Institute Certificate of Accreditation and confirmation of status from FL
Commission for Independent Education
11. Med-Life Institute Externship Affiliation Agreement
D. NCLEX documents
1. Authorization to Test, test validity: 06 December 2016 – 04 June 2017, Hawaii Board
of Nursing
2. State of Hawaii BON exam information and NCLEX Candidate Report
E. Registered Professional Nurse
1. New York License Number 760915, dated November 9, 2018
2. New York Registration Certificate, valid through 12/31/2023
3. Hawaii license renewal email
F. Post RN License Education and
1. Chamberlin University, Bachelor of Science in Nursing, Completed 10/26/2019
a. Transcript
i. Includes RN Capstone course
b. Degree
2. Continuing Education
a. Positive Workplace: Preventing Harassment at Work Fundamentals,
11/25/2022
b. 2023 SICC – Circulation and Power Devices, Excelsior Care Group,
1/14/2023
c. 2023 SICC Annual Mandatories, Staten Island Care Center, 2/6/2023
d. 2022 SICC Annual Mandatories, Staten Island Care Center, 4/8/2022
e. 2022 SICC – Circulation and Power Devices, Excelsior Care Group, 7/7/2022
f. 2021 SICC Annual Mandatories, Staten Island Care Center, 10/28/2021
G. Letters of Support
1. Letter from Regina Appiah-Mends, former Director of Nursing
• “She was the charge Nurse for a 60 bed sub-acute unit and later as the week
end supervisor. She was able to manage staffing and all issues that arise when
she was on duty. … Without reservation I highly recommend her to any
institution knowing she will be an asset.”
2. Letter from Cynthia V. San Luis, RN, BSN, Director of Nursing
• “Charity is an exemplary nurse and employee. … She is a good mentor to the
new and younger nurses, and she is also very eager to acquire more knowledge.
She knows the regulations pertaining to nursing practice; she can be relied
2
EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024
upon to perform her tasks accordingly and can be a great help to the facility
preparing for a state review.”
3. Letter from Heather A. Cooke, RN, ADON, Completecare at Laurelton
• “Charity is hard working and reliable. She has demonstrated competency in
all areas of nursing required by our various populations. You can rely on her
dedication and composure under pressure. …. Charity is an exemplary
representation of the nursing model.”
4. Letter from Angela Garcia, Director of Nursing, Staten Island Care Center
• “She has exceptional supervisorial skills. … She possesses the knowledge and
the ability to perform all duties required of a nurse, and she goes above and
beyond to make sure patients are as comfortable as possible. … During her
time working she has demonstrated tremendous dedication to her job and the
improvement of patient care.”
H. Confirmation of employment as an RN
1. Completecare @ Laurelton, per diem RN
2. Staten Island Care Center, employment as RN Supervisor
3. Richmond University Medical Center, staff nurse, child/adolescent inpatient
psychiatric unit
3
EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024
From: Beth Atwood
To: OPDPLS
Cc: Jesse Baldwin
Subject: Charity Akakpo RN License No. 760915
Date: Wednesday, November 8, 2023 10:40:00 AM
Attachments: Akakpo__Charity 11.8.2023 Submission_ltr_to_NY_OP.pdf
image001.png
Exhibit 1 - prior submission ltrs to NY OP.pdf
Exhibit 2 - INDEX OF SUPPORTING DOCUMENTATION- Akakpo, Charity.pdf
Dear Mr. Hamilton:
Attached please find correspondence from attorney Jesse Baldwin concerning our client, Charity
Akakpo, RN License No. 760915. 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 T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index
Preview
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 21 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: Charity Akakpo RN License No. 760915 Dear Mr. Hamilton: On behalf of Charity Akakpo, RN/BSN we write continuance of cooperation with your office and your inquiry about our client’s education and qualifications. Nurse Akakpo received her license as an RN in New York State on November 9, 2018, five years ago this week. Enclosed herewith is a jump drive with materials we have gathered to demonstrate Nurse Akakpo’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 subsequent letters on March 23, 2023 and April 20, 2023 concerning the circumstances of Nurse Akakpo’s graduation date predating the investigation date, which are 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. 5680 Main Street | Buffalo, New York 14221 716-475-9533 | www.acbfirm.com EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024 Nurse Akakpo’s graduation date predates the Operation Nightingale investigation period We believe your correspondence was sent to Ms. Akakpo in error, and the Nightingale investigation that resulted in your letter to Nurse Akakpo does not apply to her because she completed her RN education before the timeframe at issue. Ms. Akakpo completed her RN education program at Med Life Institute on June 19, 2015. The Interim Update posted on your website indicates the timeframe involved for Med Life Institute WBP LLC begins in October 2016, more than one year after Ms. Akakpo graduated. Copies of her 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 her best efforts, Nurse Akakpo 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, she retained a copy of her 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 Akakpo’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 Akakpo did attend and complete a nursing education program at Med Life Institute School of Nursing. The program included classroom instruction and clinical training. Nurse Akakpo passed the NCLEX. The fact that a nursing school attended by this nurse may have sold or given our fraudulent degrees to students other than Nurse Akakpo does not render this particular nurse a threat to the public health. We believe your office is aware of this fact, because more than nine months have passed since your initial letter to Nurse Akakpo and no direct action has been taken, nor has any proceeding been commenced against her license. No misconduct or other grounds for discipline Nurse Akakpo 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. 64.1(a)(2) by completing a program in nursing approved by the licensing authority of Florida for practice as a Registered Nurse. Nurse Akakpo was authorized to sit for the NCLEX and passed the exam. These were the legal requirements for obtaining her RN license. Absent any fraud on her part, there is no basis to take her license from her. 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 Akakpo 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 Akakpo already had a lifetime right to her license obtained before this change, the regulatory change cannot be applied to her retroactively. 2 EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024 Nurse Akakpo has clearly and obviously committed no fraud. The degree she 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 Akakpo completed a practical nursing program at American Health Care Inc., passed the NCLEX-PN, received her New Jersey license as a Practical Nurse and was endorsed in the State of New York as of October 4, 2018. Documents related to her LPN license and training are contained at Exhibit A on the jump drive included with this letter. Thereafter, she was enrolled in the Professional Nursing program at Jersey College. (Exhibit B) Her transcripts, LPN license, entrance examination and application fee were included as part of her admission process to Med Life Institute. Med Life Institute granted her transfer credits based on her prior education and clinical training. Nurse Akakpo attended numerous classes, all of which were in person. She travelled to Florida ten (10) times, each trip being 6 days long, for the purpose of attending classes and clinical training. Her RN education included homework, quizzes and examinations. Included in Exhibit C.1-6 is evidence confirming her enrollment, documentation of clinical hours, as well as proof of payment of the background check and travel expenses incurred in Florida. Nurse Akakpo kept some of her course materials from Med-Life Institute including the Course Syllabus/Outline for the RN Program, ASN Curriculum, various Course Syllabuses, Certificate of accreditation of Med-Life Institute with confirmation of status from the Florida Commission for Independent Education and the Externship Affiliation Agreement. (Exhibit C.7- 11) The ASN Curriculum (Exhibit C.8) includes a chart of the clinical facility, location, clinical services utilized, clinical hours and lab/simulation. Nurse Akakpo completed 945 clinical hours in Florida. Clinical sites included Tender Care Center, Lakeside Medical Center, South County Mental Health Center, Hollywood Birth Center, and Seaview Rehab & Nursing Center. The ASN Curriculum (Exhibit C.8) includes a chart of the clinical facility, location, clinical services utilized, clinical hours and lab/simulation. Prior to attending Med Life Institute, she completed over 900 clinical hours during her LPN training and clinical hours on maternity, pediatric and psychiatric nursing while enrolled at Jersey College. (Exhibits A.3 and B) Given these facts, it cannot reasonably be suggested that Nurse Akakpo participated in any fraud or made any material misrepresentations on her license application materials. Nurse Akakpo’s competence as an RN is established In addition to the education previously discussed, Nurse Akakpo continued her nursing education and earned her Bachelor of Science in Nursing, magna cum laude, from Chamberlin University in 2019, where she was required to complete a Capstone Project. (Exhibit F.1) She has completed various continuing education courses through her employment as an RN. (Exhibit F.2) Prior to earning her RN, for several years Nurse Akakpo worked as an LPN providing direct patient care at Complete Care at Laurelton (12/2019 – 4/2022); (Wendel Garden & Rehab Center (2013- 2019) and Care One at East Brunswick (2007-2013). In these various positions, her job duties 3 EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024 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 her RN, in May 2020, Nurse Akakpo transitioned to a staff nurse (RN position) with Complete Care at Laurelton. She has worked as an RN nurse supervisor at Staten Island Care Center. Her duties included assessing, observing, communicating with patients, administering medications and treatments including wound care, foley catheter insertion/care, tracheostomy care, colostomy care, gastrostomy-tube care, and IV insertions. Nurse Akakpo worked as a Staff Nurse – Behavioral with Richmond University Medical Center where her job duties included taking an active role in direct assessment and care; practicing crisis intervention; formulating individualized nursing care plans utilizing the nursing process; and assessing each resident daily and implementing a change in the course of action as needed. Nurse Akakpo’s colleagues and supervisors describe Nurse Akakpo as an “exemplary nurse” who “has demonstrated competency in all areas of nursing required our various populations.” She is described as composed under pressure, goes above and beyond to “make sure patients are as comfortable as possible.” She is described as loyal, possessing leadership and organizational skills in managing both clinical and non-clinical issues. Nurse Akakpo has also been described as being a great help in preparing the facility for State review and having “worked through the toughest of time.” (Exhibit G). Conclusion For the reasons stated above, and based on the evidence enclosed, it is clear Nurse Akakpo 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. 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 Akakpo’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 T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024 INDEX OF SUPPORTING DOCUMENTATION ON BEHALF OF CHARITY AKAPO, RN School Attended: Med-Life Institute Dates of Attendance: 6/19/2014 – 6/19/2015 A. Licensed Practical Nurse 1. State of New Jersey LPN License, registration valid through 5/31/2023 2. Endorsed in New York, October 4, 2018 3. American Health Care Inc. a. Transcript B. Previous Education 1. Jersey College a. Transcript b. Letter from Jersey College confirming completion of practicum courses C. Med Life Institute School of Nursing 1. Transcript, dates attended: 6/19/2014 – 6/19/2015 2. Associates of Science of Nursing, Degree, dated 6/19/2015 3. Confirmation of Enrollment and Tuition, 2/23/2015 4. DocuNow receipt for background check and drug test 5. Clinical Hours documentation a. Letter from Med-Life confirming acceptance of students at facility b. Clinical/Experiential Learning Evaluation form, Tallwoods Care Center, Bayville, NY, 40 hours, 6/8 – 6/12/2015 6. Evidence of travel expenses a. Receipts b. Avis Car Rental Agreement c. National Car Rental Agreement d. Comfort Inn & Suites, Room reservations e. Conference and Lodging Center, reservation confirmation f. Bank records 7. Med-Life Institute Course Syllabus/Outline for RN Program 2014-2015 8. Med-Life Institute ASN Curriculum – Total Courses and Credits Earned 9. Course Syllabus 2015 a. Fundamentals of Nursing, NUR 201 1 EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024 b. Maternal Newborn Nursing, NUR 205 c. Pediatric Nursing, NUR 207 10. Med-Life Institute Certificate of Accreditation and confirmation of status from FL Commission for Independent Education 11. Med-Life Institute Externship Affiliation Agreement D. NCLEX documents 1. Authorization to Test, test validity: 06 December 2016 – 04 June 2017, Hawaii Board of Nursing 2. State of Hawaii BON exam information and NCLEX Candidate Report E. Registered Professional Nurse 1. New York License Number 760915, dated November 9, 2018 2. New York Registration Certificate, valid through 12/31/2023 3. Hawaii license renewal email F. Post RN License Education and 1. Chamberlin University, Bachelor of Science in Nursing, Completed 10/26/2019 a. Transcript i. Includes RN Capstone course b. Degree 2. Continuing Education a. Positive Workplace: Preventing Harassment at Work Fundamentals, 11/25/2022 b. 2023 SICC – Circulation and Power Devices, Excelsior Care Group, 1/14/2023 c. 2023 SICC Annual Mandatories, Staten Island Care Center, 2/6/2023 d. 2022 SICC Annual Mandatories, Staten Island Care Center, 4/8/2022 e. 2022 SICC – Circulation and Power Devices, Excelsior Care Group, 7/7/2022 f. 2021 SICC Annual Mandatories, Staten Island Care Center, 10/28/2021 G. Letters of Support 1. Letter from Regina Appiah-Mends, former Director of Nursing • “She was the charge Nurse for a 60 bed sub-acute unit and later as the week end supervisor. She was able to manage staffing and all issues that arise when she was on duty. … Without reservation I highly recommend her to any institution knowing she will be an asset.” 2. Letter from Cynthia V. San Luis, RN, BSN, Director of Nursing • “Charity is an exemplary nurse and employee. … She is a good mentor to the new and younger nurses, and she is also very eager to acquire more knowledge. She knows the regulations pertaining to nursing practice; she can be relied 2 EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024 upon to perform her tasks accordingly and can be a great help to the facility preparing for a state review.” 3. Letter from Heather A. Cooke, RN, ADON, Completecare at Laurelton • “Charity is hard working and reliable. She has demonstrated competency in all areas of nursing required by our various populations. You can rely on her dedication and composure under pressure. …. Charity is an exemplary representation of the nursing model.” 4. Letter from Angela Garcia, Director of Nursing, Staten Island Care Center • “She has exceptional supervisorial skills. … She possesses the knowledge and the ability to perform all duties required of a nurse, and she goes above and beyond to make sure patients are as comfortable as possible. … During her time working she has demonstrated tremendous dedication to her job and the improvement of patient care.” H. Confirmation of employment as an RN 1. Completecare @ Laurelton, per diem RN 2. Staten Island Care Center, employment as RN Supervisor 3. Richmond University Medical Center, staff nurse, child/adolescent inpatient psychiatric unit 3 EXHIBIT T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 02/21/2024 From: Beth Atwood To: OPDPLS Cc: Jesse Baldwin Subject: Charity Akakpo RN License No. 760915 Date: Wednesday, November 8, 2023 10:40:00 AM Attachments: Akakpo__Charity 11.8.2023 Submission_ltr_to_NY_OP.pdf image001.png Exhibit 1 - prior submission ltrs to NY OP.pdf Exhibit 2 - INDEX OF SUPPORTING DOCUMENTATION- Akakpo, Charity.pdf Dear Mr. Hamilton: Attached please find correspondence from attorney Jesse Baldwin concerning our client, Charity Akakpo, RN License No. 760915. 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 T - Akakpo, C - 11.8.2023 Baldwin-Hamilton w index