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Department of
SOCIAL SERVICES

Community Care Licensing


COMPLAINT INVESTIGATION REPORT

Facility Number: 300600977
Report Date: 08/25/2026
Date Signed: 08/25/2026 11:16:46 AM

Substantiated


STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT		CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 770 THE CITY DR., SUITE 7100
ORANGE, CA 92868
This is an official report of an unannounced visit/investigation of a complaint received in our office on
05/01/2026 and conducted by Evaluator Kimberly Lyman
COMPLAINT CONTROL NUMBER: 22-AS-20260501153636
FACILITY NAME:TOWN & COUNTRYFACILITY NUMBER:
300600977
ADMINISTRATOR:SARA MODUGNOFACILITY TYPE:
741
ADDRESS:555 E. MEMORY LANETELEPHONE:
(714) 547-7581
CITY:SANTA ANASTATE: CAZIP CODE:
92706
CAPACITY:328CENSUS: 82DATE:
08/25/2026
UNANNOUNCEDTIME BEGAN:
09:55 AM
MET WITH:Cristina Garcia and Stephanie JukicTIME COMPLETED:
11:45 AM
ALLEGATION(S):
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Staff illegally evicted a resident in care
INVESTIGATION FINDINGS:
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Licensing Program Analyst (LPA) Kimberly Lyman conducted an unannounced complaint visit to deliver findings on the above allegations. LPA was greeted and granted entry into the facility and explained the reason for the visit.
During the course of the investigation, LPA toured the facility and interviewed staff and witness as well as reviewed and obtained documentation such as eviction notice. Regarding the allegation that staff illegally evicted a resident in care, the investigation revealed the following: On April 30, 2026, facility served a thirty-day eviction notice to Resident 1’s (R1) responsible party. Per review of notice, notice is missing pertinent information such as unlawful detainer verbiage, relocation assistance and department information which required by regulation rendering the notice as unlawful. Facility did not forward the notice to the department. Based on record review, the preponderance of evidence standard has been met. Therefore, the above allegation is deemed SUBSTANTIATED as per the Title 22, Division 6, Chapter 8 of the California Code of Regulations. Deficiency is being cited on the attached LIC-9099D.
An exit interview was conducted and a copy of this report as well as the appeal rights were provided at exit.
Substantiated
Estimated Days of Completion:
SUPERVISORS NAME: Alisa Ortiz
LICENSING EVALUATOR NAME: Kimberly Lyman
LICENSING EVALUATOR SIGNATURE:

DATE: 08/25/2026
I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:

DATE: 08/25/2026
This report must be available at Child Care and Group Home facilities for public review for 3 years.
LIC9099 (FAS) - (06/04)
Page: 1 of 7
Control Number 22-AS-20260501153636
STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)		CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 770 THE CITY DR., SUITE 7100
ORANGE, CA 92868

FACILITY NAME: TOWN & COUNTRY
FACILITY NUMBER: 300600977
DEFICIENCY INFORMATION FOR THIS PAGE:
VISIT DATE: 08/25/2026
Deficiency Type
POC Due Date /
Section Number
DEFICIENCIES
PLAN OF CORRECTIONS(POCs)
Type B
09/08/2026
Section Cited
HSC
1569.683(a)(4)
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In addition to complying with other applicable regulations, a licensee of a residential care facility for the elderly who sends a notice of eviction to a resident shall set forth in the notice to quit the reasons relied upon for the eviction... This req is not met as evidenced by:
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Licensee agrees to read the regulation and forward a statement of understanding to LPA by POC due date.
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Based on record review, Licensee failed to ensure facility provided a proper eviction notice to R1 and the department that included unlawful detainer verbiage, department information and relocation assistance which poses a potential health and safety risk to residents in care.
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Failure to correct the cited deficiency(ies), on or before the Plan of Correction (POC) due date, may result in a civil penalty assessment.
SUPERVISOR'S NAME: Alisa Ortiz
LICENSING EVALUATOR NAME: Kimberly Lyman
LICENSING EVALUATOR SIGNATURE:

DATE: 08/25/2026
I acknowledge receipt of this form and understand my appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:

DATE: 08/25/2026
LIC9099 (FAS) - (06/04)
Page: 2 of 7
STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT		CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 770 THE CITY DR., SUITE 7100
ORANGE, CA 92868
This is an official report of an unannounced visit/investigation of a complaint received in our office on
05/01/2026 and conducted by Evaluator Kimberly Lyman
COMPLAINT CONTROL NUMBER: 22-AS-20260501153636

FACILITY NAME:TOWN & COUNTRYFACILITY NUMBER:
300600977
ADMINISTRATOR:SARA MODUGNOFACILITY TYPE:
741
ADDRESS:555 E. MEMORY LANETELEPHONE:
(714) 547-7581
CITY:SANTA ANASTATE:CAZIP CODE:
92706
CAPACITY:328CENSUS: 82DATE:
08/25/2026
UNANNOUNCEDTIME BEGAN:
09:55 AM
MET WITH:Cristina Garcia and Stephanie JukicTIME COMPLETED:
11:45 AM
ALLEGATION(S):
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Staff neglected a resident resulting in a fracture while in care
Staff caused an injury to a resident in care
Staff did not seek medical attention for a resident in care in a timely manner
Staff did not assist a resident in care
INVESTIGATION FINDINGS:
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Licensing Program Analyst (LPA) Kimberly Lyman conducted an unannounced complaint visit to deliver findings on the above allegations. LPA was greeted and granted entry into the facility and explained the reason for the visit.
During the course of the investigation, LPA toured the facility and interviewed staff and witness.
Regarding the allegations that Staff neglected a resident resulting in a fracture while in care, Staff caused an injury to a resident in care, Staff did not seek medical attention for a resident in care in a timely manner and Staff did not assist a resident in care, the investigation revealed the following: Per physician report dated January 05, 2026, Resident 1 (R1) is diagnosed with Dementia with behavioral disturbances. Resident Appraisal dated October 31, 2023, shows R1 had a fall prior to admittance to facility which resulted in a fractured pelvis. The resident is not deemed a fall risk per Needs and Services Appraisal dated November 16, 2023. On November 06, 2024, Facility reported that the resident had an un-witnessed fall in the resident’s room in which the resident stated they had attempted to pick up a paper on the floor and got light-headed. CONT ON LIC 9099C DATED 08/25/2026
Unsubstantiated
Estimated Days of Completion:
SUPERVISORS NAME: Alisa Ortiz
LICENSING EVALUATOR NAME: Kimberly Lyman
LICENSING EVALUATOR SIGNATURE:

DATE: 08/25/2026
I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:

DATE: 08/25/2026
This report must be available at Child Care and Group Home facilities for public review for 3 years.
LIC9099 (FAS) - (06/04)
Page: 3 of 7
Control Number 22-AS-20260501153636
STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)		CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 770 THE CITY DR., SUITE 7100
ORANGE, CA 92868
FACILITY NAME: TOWN & COUNTRY
FACILITY NUMBER: 300600977
VISIT DATE: 08/25/2026
NARRATIVE
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The resident was sent out to the Hospital. Review of hospital discharge paperwork shows resident was hospitalized from November 06- November 09, 2024, for “Fractures of the right superior and inferior pubic rami with chronic deformities of the left superior and inferior pubic rami.” There is no evidence of fractures of the right iliac and sacrum. Four out of four staff interviewed state there was always staff with R1 unless the resident was sleeping; however this incident was reported as “Unwitnessed” per incident report. The resident’s family expected staff to always be with the resident and staff obliged per management directive. There was not a specified one on one, it was just understood per family request that a caregiver would be with the resident at all times. Four out of four staff deny the resident was neglected as R1 was continually observed. The resident was always in the activity room and not in the resident’s room as the family demanded the resident was to be kept out of the resident’s room. Appraisal Needs and Services dated November 16, 2023, does not show the resident as a fall risk. On December 29, 2023, facility reported the resident was carrying a laundry basket with the walker when a caregiver assisted the resident back to the room. The resident ended up falling and receiving a skin tear on the knee. First aid was applied. R1 subsequently reported that the caregiver had been rough with them. Facility initiated an investigation and the incident was reported to the family who declined any further action or medical care per facility notes. Four out of four staff deny knowledge of a caregiver being rough with the resident. Facility notes indicate R1 had a fall without an injury on March 22. 2026. Four out of four staff state assisting the resident with toileting and staff were always with the resident. Per facility notes and incident report, R1 requested to sit on patio on September 02, 2024. Staff documented bringing the resident water. When the resident was brought in, R1 had low energy, was warm and red. 911 was called and resident was sent out to the hospital. R1 was subsequently hospitalized for confusion, covid and heat exhaustion. Per Appraisal dated November 16, 2023, R1 was alert and oriented and able to make their needs known. Four out of four staff deny knowledge of how long resident was outside but state the patio is always visible so the resident would not be out of visual range. LPA observed patio is observable from the common area. Staff state R1 preferred to stay on the patio and would protest when staff would bring the resident back in. CONTINUED ON LIC 9099C DATED 08/25/2026
SUPERVISORS NAME: Alisa Ortiz
LICENSING EVALUATOR NAME: Kimberly Lyman
LICENSING EVALUATOR SIGNATURE:

DATE: 08/25/2026
I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:

DATE: 08/25/2026
LIC9099 (FAS) - (06/04)
Page: 4 of 7
Control Number 22-AS-20260501153636
STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)		CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 770 THE CITY DR., SUITE 7100
ORANGE, CA 92868
FACILITY NAME: TOWN & COUNTRY
FACILITY NUMBER: 300600977
VISIT DATE: 08/25/2026
NARRATIVE
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Based on records reviewed and interviews conducted, LPA is unable to corroborate the allegations. Therefore, the allegations are deemed unsubstantiated, meaning that although the allegations may have happened or are valid, there is not a preponderance of the evidence to prove that the alleged violations occurred. Exit interview was conducted and copy of the report was provided to the facility.
SUPERVISORS NAME: Alisa Ortiz
LICENSING EVALUATOR NAME: Kimberly Lyman
LICENSING EVALUATOR SIGNATURE:

DATE: 08/25/2026
I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:

DATE: 08/25/2026
LIC9099 (FAS) - (06/04)
Page: 5 of 7
STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT		CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 770 THE CITY DR., SUITE 7100
ORANGE, CA 92868
This is an official report of an unannounced visit/investigation of a complaint received in our office on
05/01/2026 and conducted by Evaluator Kimberly Lyman
COMPLAINT CONTROL NUMBER: 22-AS-20260501153636

FACILITY NAME:TOWN & COUNTRYFACILITY NUMBER:
300600977
ADMINISTRATOR:SARA MODUGNOFACILITY TYPE:
741
ADDRESS:555 E. MEMORY LANETELEPHONE:
(714) 547-7581
CITY:SANTA ANASTATE:CAZIP CODE:
92706
CAPACITY:328CENSUS: 82DATE:
08/25/2026
UNANNOUNCEDTIME BEGAN:
09:55 AM
MET WITH:Cristina Garcia and Stephanie JukicTIME COMPLETED:
11:45 AM
ALLEGATION(S):
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Staff did not notify resident's responsible party of a scabies outbreak
Staff did not report incidents to licensing
INVESTIGATION FINDINGS:
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Licensing Program Analyst (LPA) Kimberly Lyman conducted an unannounced complaint visit to deliver findings on the above allegations. LPA was greeted and granted entry into the facility and explained the reason for the visit.
During the course of the investigation, LPA toured the facility and interviewed staff and witness as well as reviewed and obtained pertinent documentation such as incident reports. Regarding the allegations that Staff did not notify resident's responsible party of a scabies outbreak and Staff did not report incidents to licensing, the investigation revealed the following: In September 2025, facility experienced a scabies outbreak. Facility notified responsible parties of all residents by email on September 9, 12, and 19, 2025 and provided the documentation to LPA. Residents responsible parties with suspected scabies received a phone call from facility. The Department fully investigated the reporting of the scabies outbreak in September 2025 in complaint #22-AS-20250904143853 which revealed the facility was reporting the outbreak to responsible parties in the facility as well as public health. CONTINUED ON LIC 9099C DATED 08/25/2026
Unfounded
Estimated Days of Completion:
SUPERVISORS NAME: Alisa Ortiz
LICENSING EVALUATOR NAME: Kimberly Lyman
LICENSING EVALUATOR SIGNATURE:

DATE: 08/25/2026
I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:

DATE: 08/25/2026
This report must be available at Child Care and Group Home facilities for public review for 3 years.
LIC9099 (FAS) - (06/04)
Page: 6 of 7
Control Number 22-AS-20260501153636
STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

COMPLAINT INVESTIGATION REPORT (Cont)		CALIFORNIA DEPARTMENT OF SOCIAL SERVICES
COMMUNITY CARE LICENSING DIVISION
CCLD Regional Office, 770 THE CITY DR., SUITE 7100
ORANGE, CA 92868
FACILITY NAME: TOWN & COUNTRY
FACILITY NUMBER: 300600977
VISIT DATE: 08/25/2026
NARRATIVE
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LPA reviewed incident reports provided for all incidents noted in alleged allegations thus facility has been reporting the incidents. Based on record review, the allegations are deemed UNFOUNDED, meaning that the allegations were false, could not have happened and/or is without a reasonable basis. Exit Interview conducted and a copy of this report was provided.
SUPERVISORS NAME: Alisa Ortiz
LICENSING EVALUATOR NAME: Kimberly Lyman
LICENSING EVALUATOR SIGNATURE:

DATE: 08/25/2026
I acknowledge receipt of this form and understand my licensing appeal rights as explained and received.
FACILITY REPRESENTATIVE SIGNATURE:

DATE: 08/25/2026
LIC9099 (FAS) - (06/04)
Page: 7 of 7