The 89-page document makes a range of claims about Wake Forest Care Center, including that medication was given incorrectly to residents nearly 20 percent of the time and unlicensed or unqualified people were watching and giving medication to patients.
It says one patient went three days without medication because they were "unavailable, waiting for delivery from pharmacy."
It also claims residents fell and were hurt because they weren't given body alarms and residents kept walking away through a door that wasn't fitted with an alarm.
A judge has temporarily blocked the NC Department of Health and Human Services from shutting down the center.
Friday, WFCC owner Richard Cresenzo obtained a temporary restraining order blocking the action.
In a complaint filed in Wake County Superior Court, Cresenzo said to the best of his knowledge, "deficiencies were rectified and addressed as promptly as possible."
Nearly 70 people live at the assisted living facility which is located in the 300-block of South Allen Road.
It is the same place where a 79-year-old man wandered away and died last month. Another person died after walking away from the center back in 2006.
Cresenzo's legal complaint stated he has 20 days to appeal the order to move residents out of his facility and he intends to do so.
A hearing is scheduled for Jan. 17.