complaint·September 3, 2025

provided information that supports the complaint allegations. During interviews, Registered Nurse 1 (RN1) confirmed they were notified on April 11, 2024, regarding a small skin tear on the right arm of R1. After responding to the facility, RN1 observed the smaller skin tear to the right arm, and an additional larger skin tear on R1’s left arm. RN1 explained, R1 sustained small skin tears before, but not to the degree of what R1 sustained on April 11, 2024. RN1’s medical opinion is that both skin tears occurred at the same time and were fresh. RN1 stated, it’s reasonable to believe the bruise observed on R1’s forehead was also sustained at the same time of the skin tears. Per information gathered from Licensee – Kathy Maghbouleh (S10), on April 11, 2024, S1 was present in the facility when R1 sustained a small cut to the right arm. According to Licensee Maghbouleh, they helped put a bandage on the smaller cut to R1’s right arm. Licensee Maghbouleh claimed an unidentified caregiver told S1 the skin tear occurred during a transfer. The unidentified caregiver explained to Licensee Maghbouleh, that R1 has no muscle control and can easily lean forward while in the wheelchair and hit their head. Licensee Maghbouleh claims this is probably how R1 sustained the bruise on the forehead. The unidentified caregiver told Licensee Maghbouleh, they did not see the larger cut on the left arm, and suggested, maybe the hospice nurse who responded to the facility caused the cut on the left arm. Per the information gathered from Witness 1 (W1), after R1 sustained unexplained cuts and bruises on April 11, 2024, W1 and Licensee Maghbouleh came to a verbal agreement. Licensee Maghbouleh allowed W1 to place a camera in R1’s room after the resident sustained “unexplained injuries.” Shortly after the camera was placed in the resident’s room, on April 14, 2024, a video was recorded that showed a caregiver handling R1 in an aggressive manner while changing the resident. The video recording of the caregiver (now Former Caregiver 1 – FC1) handling R1 was provided for review. Per information provided by Staff 5 (S5), FC1 was unaware a surveillance camera was installed in R1’s room. FC1 was recorded changing R1’s diaper and flipped R1 like a piece of paper. Licensee Maghbouleh confirmed the verbal agreement with W1 for a camera to be placed in R1’s room after R1 sustained injuries on April 11, 2024; furthermore, S1 (licensee) confirmed FC1 was terminated after the video recording that shows the former caregiver handling R1 in a rough manner. Continued on LIC812C page 2 of 3 During subsequent interviews to clear up discrepancies discovered during the investigation, three facility staff members including Licensee Maghbouleh admitted to providing false statements regarding the details of the fall that occurred on April 11, 2024. Licensee Maghbouleh, S3, and S6, all admitted R1 was found on the floor with a skin tear after being left alone in their wheelchair. Licensee Maghbouleh, S3, and S6, all admitted to providing false statements during previous interviews. It was confirmed, not only were false statements provided to the department during the course of a complaint investigation, but a hospice nurse was falsely accused or "suggested" to be responsible for causing the larger skin tear to R1 when Licensee Maghbouleh, S3, and S6 all knew the statement and/or suggestion that the hospice nurse was responsible for the large skin tear was false. Based on the evidence gathered through interview confirmation, document review, staff’s own admissions, and video review, the preponderance of evidence standard has been met, therefore, all three allegations listed above are found to be SUBSTANTIATED. Violations are being cited per California Code of Regulations Title 22, Division 6. An immediate Civil Penalty is being assessed today in the amount of five hundred dollars ($500). An additional Civil Penalty is pending determination by Community Care Licensing Division as per Health & Safety Code 1569.49(f). An exit interview was conducted, and a copy of this report and appeal rights were provided. Page 3 of 3