COMMONWEALTH OF PENNSYLVANIA POLICE CRIMINAL COMPLAINT COUNTY OF: LEBANON. seh COMMONWEALTH OF PENNSYLVANIA Magisterial District Number: 52-2-03 vs. MDJ: Hon, KIM WOLFE DEFENDANT: (NAME and ADDRESS): Address; 1720 STATE ROUTE 72 NORTH COURTNEY ‘STASH LEBANONICLEONA PA 17046 Fist Nam Wise Name Last Nae 485 STRACK DRIVE MYERSTOWN PA 17067 Telephone: 717-273-0024 [NCIC Exadition Code Type Felony Fat Zh aFeony No Ext, Ti e.isdemeanar Lied Ti e-sdemeanor Pending Dh2-Fetony Le, Os-Fetony Pend. Clc-misdemeanor Surrounding States 1 Distance: D)3-Feony Suroundng States Di Aaiscereanor Ful To.misdomasnor No Etradon ‘DEFENDANT IDENTIFICATION INFORMATION Docket Number Date Fled | OTWLtecan Humber | onplantnet Humber [50 Request Lab Services? iz 17-0000263. Z Oves (no GENDER | pow a/t7ito89 | PoB “aa DOB [ee-Defendents) Date Fist Name Wisco Name LastName Gen, frome | aKa RACE wit DlAsion OB Di Native American D1 unknown ETHNICITY) Hispenie EH Nortispanio Dunkrown HAIR COLOR Darian Eyre (rewauiny — C)sov(Sanay) CL] etu (eum True ray [lero row) Derxise) — Cl oxcormey — EXwnyviniey El ox cunissaly Eh orn icren) Eprom) BLN (Gere Stavoory) eat zt EVE COLOR Dex eter) Ziewu eve) Tako (aroun Lan (Green) Dery (cay) i nrc ian lnnarinarooy Eleni rar anssetres) E00. cucnn) Driver License | State License Number [Espires: ‘WEIGHT (be) DNA Yes MNO | DNA Location 140. FBI Number MN Number FLHEIGHT in| Defendant Fingerprinted! | LIVES LINO a z S12 Fingerprint Classification = DEFENDANT VEHICLE INFORMATION Pate State [Hazmat | _ Registration Commiven. | Sehost py] Oih- NCIC Veh. Code] Res. TI _| sticker (ayy) ind Veh same vin Year| Make Mogel ‘Sue Color | as bet o Office of the attorney for the Commonwealth [1 Approved O Disapproved because: Ta CORT ay Sa SA EE ESR FS RS OAT Ts TTR FS TS FER ‘Name of th attorney forthe CommonwealinPrease Print or Type) (Signature ofthe aiomey for the Commonwealy 261751 |, DETECTIVE TODD HIRSCH (ame ofthe Aint) ‘of Lebanon County Detective Bureau (entfy Department or Agency Represented and Pltical Subdivision) do hereby state: (check appropriate box) 1. Ml accuse the above named defendant who lives at the address set forth above DI accuse the defendant whose name is unknown to me but who is described as PA0382100 (Poice Agency ORI Number) Tale} (PSPIMPOETC Assigned Aftant ID Number & Badge # C1 | accuse the defendant whose name and popular designation or nickname are unknown to me and whom I have therefore designated as John Doe or Jane Doe with violating the penal laws of the Commonwealth of Pennsylvania at[ 209] (Subdivision Cos 185 STRACK DRIVE, MYERSTOWN PA 17067 in LEBANON County [ 38 (County Code) ‘AOPC 412A — Rev. 07/10 NORTH LEBANON, (Place-Poltcal Subavison) Jon or about 04/24/2017 20:00 to 04/26/2017 07:30 Page 1 of 23488 POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: ‘OTNiLiveScan Number ‘Complaint/incident Number 17-0000283 First: Middle: Last Defendant Name | COURTNEY SASH 2. | ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges | have made. 3. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S.§4904) relating to unsworn falsification to authorities. 4. This complaint consists of the preceding page(s), numbered 1 through 23, The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the Commonwealth ‘of Pennsylvania and were contrary to the Act(s) of the Assembly, or in violation of the statutes cited. {Before a warrant of arrest can be issued, an affidavit of probable cause must be completed, sworn to before the issuing authority, and attached.) (Datey (Signature of Affianiy AND NOW, on this date | certify that the complaint has been properly completed and verified An affidavit of probable cause must be completed before a warrant can be issued. 523.03, (Magistorial District Court Number) {Issuing Authority Page 2 of 23 AOPC 412A ~ Rev. 07/10as POLICE CRIMINAL COMPLAINT Docket Number: | Date Filed: ‘OTWiLiveScan Number ‘Complaintiincident Number 17-9000263 Fist iddle Last Defendant Name | COURTNEY STASH The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically. (Set forth a rior summary ofthe Facts sufcient to advise the defendant ofthe nature of the offense(s) charged. A citation tothe statutes) allogedy Violated, without more, is not sufficient. Ina summary case, you must ete the specie section(s) and subsecton(a) of the etatut(s) or ordinance(s) allegedly “clad Te age fh tat tintin a tree na oe nsesae races aac oe see aaah errant) teed SOURS Bact tical re tcetnc nae b esas ess ketiaagaar an panama Trahoate | Ey Atamet Saitaon Conspiroey oS Ee nes ali [esos [a Wall] Tue 18 1 re aa "sal Bai, as aa — a — aa ee — re PennDOT Data | Accent (applicable) | Nonber Cseieyzme work zane Statute Description (include the name of statute or ordinance): INVOLUNTARY MANSLAUGHTER ‘Acts of the accused associated with this Offense: PACC 2504 Involuntary Manslaughter M-1 IN THAT, on or about said date, THE DEFENDANT, Courtney Stash DOB: 08/17/1989, acting as a principal and/or accomplice, did commit the offense of criminal homicide constituting involuntary manslaughter by causing the death of Eoin Inchoate Attempt 7 Solicitation. Conspiracy Ortonse | 17s sora Oreo Osst08 ole [asm Ja Ge | te 16 1 2 a Gia Sein Tass Ge] Sas — “Ga — Hoa Go — ve Teodor aia | Aeon peop ae | | Cisetay zoe Cvrk zine Saute Description (nclude the name of statute or ordinance) INVOLUNTARY MANSLAUGHTER ‘Acts of the acoused associated with this Offense: Criminal Conspiracy to Commit PACC 2504 Involuntary Manslaughter M-1 IN THAT, on or about said date, THE DEFENDANT, Courtney Stash DOB: 08/17/1989, did conspire with Justin Dwyer DOB: (06/24/1988, to commit the offense of criminal homicide constituting involuntary manslaughter by causing the death of Eoin ‘AOPC 412A — Rev. 07/10 Page 3 of 23aa POLICE CRIMINAL COMPLAINT ‘Statute Description (include the name of statute or ordinance): AGGRAVATED ASSAULT ‘cis of the accused associated with this Offense: PACC Section 2702 (a) (9) Aggravated Assault - F1 In that on or about said date, the Defendant, Courtney Stash DOB: 08/17/1989, did, acting as a principal and/or accomplice, attempt to cause or intentionally, knowingly or recklessly causes serious bodily injury to @ child less than 13 years of age, by Rae pat coon cosy Sacooe | CSP Ossi Oigees of: [rm |» BB) v0 aT tia cae tia Te Fe tas — ak — Ra ae TTC Foaeernae aa (ifapplicabley | Number Csatery Zone Dlwikzane Statute Description (include the name of statute or ordinance): sccm ‘Acts of the accused associated with this Offense: Criminal Conspiracy to Commit PACC Section 2702 (a) (9) Aggravated Assault F-1 In that on or about said date, the Defendant, Courtney Stash DOB: 08/17/1989, did conspire with Justin Dwyer DOB: 06/24/1988, to attempt to cause or intentionally, knowingly or recklessly cause serious bodily injury to a child less than 13 Tacoaie | Eatet son Eonar Crenaee | O7SSSPs oie Ors als female vim | tes 1 |e teat Sian a Seu Ts] —Garg Gk aroma — TET PemnDOTData | as Ganncabie) | Rone Cisse zne Dive zoo ‘Statute Description (include the name of statute or ordinance): AGGRAVATED ASSAULT ‘Acts of the accused associated with this Offense: PACC Section 2702 (a) (8) Aggravated Assault F-2 In that on or about said date, the Defendant, Courtney Stash DOB: 08/17/1989, did, acting as @ principal andlor accomplice, attempt to cause or intentionally, knowingly or recklessly causes bodily injury to a child less than six years of age, by a person ‘AOPC 412A — Rev. 07/10 Tact Wana: ai Fe Cries eeer Carsten ot Wt are rae or i betenantname | ESdimicy a | Attempt Solicitation _ Conspiracy Caer ose Ose | voor Ga ee TERETE a aa nora ‘pplicable) | Number Lisetey zone wer zone#8 POLICE CRIMINAL COMPLAINT Docket Number: | Date Filed: ‘OTNILiveScan Number Complaintincident Number 17-0000263) Fist aida! Last. Defendant Name COURTNEY ‘STASH Inchoate | -jAstempt tation Conspiracy Offens Ofeeora 18.9024 Diese cle — Jzrozale oftne | Tite 18 | 1 F2 ses? “OfenstSecion sues PA Siaiie (ie) Couns Gade WEIS Ofensa Code UORINERS Cola PennDOT Data | acct pemner De ee Lisatey zone Two zone Statute Description (include the name of statute or ordinance): AGGRAVATED ASSAULT ‘Acts of the accused associated with this Offense: Criminal Conspiracy to Commit PAC Section 2702 (a) (8) Aggravated Assault F-2 In that on or about said date, the Defendant, Courtney Stash DOB: 08/17/1989, did conspire with Justin Dwyer DOB: (06/24/1988, to attempt to cause or intentionally, knowingly or recklessly causes bodily injury to @ child less than six years of Tnchoate | [Attempt Soletation Conspiracy Offense: Ofetora Osco Oreos alr — Jamz Jer ofthe | Tite 18 1 Fe esse Oise Seaion Subsea PA Saiue (ie) Come Grate NOI Ofenes Cade UCRNBRS Cate PennDOT Data | Accident (fapplicable) | Number Osetey zone Diwerk zone ‘Statute Description (include the name of statute or ordinance): UNLAWFUL RESTRAINT ‘Acts of the accused associated with this Offense: PACC 2902 (C) (1) Unlawful Restraint F-2 Unlawful restraint of minor where offender is victim's parent: Inchoate | [Attempt ‘Solicitation [Conspiracy Gttonse_| Tesora 1024 ONS o08 | cols — 202 Jer ‘ofthe | Tite 18 1 F2 enc? OiznatSecion_——Subseion PA Sima) — Gaus Gace N16 Ofens Gods UGRNIBAS Cove PennDOT Data | Accident, (ifapplicabiey | Number Lisetety zone lives Statute Description (include the name of statute or ordinance): UNLAWFUL RESTRAINT ‘cis of the accused associaied with this Offense: Criminal Conspiracy to Commit PAC 2902 (C) (1) Unlawful Restraint F-2 Unlawful restraint of minor where offender is victim's parent: “AROPC 412A — Rev. 07/10 Page 5 of 23#8$ POLICE CRIMINAL COMPLAINT ‘Docket Number: Date Filed: OTN/LiveScan Number ‘Complainv/incident Number ‘7.000028 Fist Tider ast: Defendant Name COURTNEY ‘STASH Inchoate ] [jAttomot Solicitation (Conspiracy ortense | Oss a011 Oreo Ors'08 ole 4304 ‘ofthe | Tile 18 1 FS Lease _Oizeat Sesion Subset FASaue (Tie) Cons Grae NGI Ofense Gade UCRIVBRS Cate PennDOT Data | Acsaent (if applicable) Number Disatety zone work zone ‘Statute Description (include the name of statute or ordinance): ENDANGERING WELFARE OF CHILDREN ‘Acts of the accused associated with this Offense: PACC 4304 (a) (1) ENDANGERING WELFARE OF CHILDREN F-3 IN THAT, on or about said date, being a parent, guardian, or other person supervising the welfare of Eoin Dwyer DOB: 12/25/2014, a child under the age of 18 years of age, THE DEFENDANT, Courtney Stash DOB: 08/17/1989, did, acting as a Inchoate | [jAtiompt Solicitation \Conspiracy Offense | V7a.901 Oiecoon Osseo [1 — ]4304 ofthe | Tite 18 1 F3 Leas? _Gfarsat Sesion Sibson PA Sima (a) Couns Gade NIG Ofas Code UGRRIBRS Code PonnDOT Data | Accident (ifapplicabie) | Number Csatety Zone Dwakene ‘Statute Description (include the name of statute or ordinance): ENDANGERING WELFARE OF CHILDREN ‘Acts of the accused associated with this Offense: Criminal Conspiracy to Commit PACC 4304 (a) (1) ENDANGERING WELFARE OF CHILDREN F-3 IN THAT, on or about said date, being a parent, guardian, or other person supervising the welfare of Eoin Dwyer DOB: 12125/2014, a child under the age of 18 years of age, THE DEFENDANT. Courtney Stash DOB: 08/17/1989, did conspire inchoate | EjAtvonpt Soliton Conspiracy Oftense | TVo00ra Oresco ONese8 oj 2701 | At ofthe | Title 18 1 Mt sc? Dienst Ses Secon Fi Sis Ti) — Gaia Ge NEVE Oferse Code UGRNBRS Coe PennDOT Data | Accent (ifapplicable) | Number Osafety Zone Dwerk zone Statute Description (include the name of statute or ordinance): SIMPLE ASSAULT-GENERAL ‘Acts of the accused associated with this Offense: PACC, SECTION 2701 (a) (1) SIMPLE ASSAULT M-1 In that the above named actor did on or about said date, acting as a principal and/or accomplice, did attempt to cause or intentionally, knowingly, or recklessly causes bodiy injury to another To Wit: Eoin Dwyer DOB: 12/25/2014, being a ‘AOPC 412A — Rev. 07/10 Page 6 of 23288 POLICE CRIMINAL COMPLAINT Docket Number: | Date Filed: OTWiLiveSean Number ‘Complaintineldent Number 117-0000263 First Middle: Last Defendant Name | COURTNEY STASH Inchoate | [Attomet Solicitation Conspiracy Ottense | Tesora Die onan Orso08 O}re favor fat ofthe | Tile 18, 1 mt Lead? _Gierseh_Seeion Subse PASisha (ie) Cou Grade NIE Ofonse Code UCRNVBRS Code PennDOT Data | Acddent (ifapplicable) | Number Oisetety Zone Divan zone ‘Statute Description include the name of statute or ordinance): ‘SIMPLE ASSAULT-GENERAL ‘Acts of the accused associated with this Offense: Criminal Conspiracy to Commit PACC, SECTION 2701 (a) (1) SIMPLE ASSAULT M-1 In that the above named actor did on or about said date, conspire with Justin Dwyer DOB: 06/24/1988, to attempt to cause or intentionally, knowingly, or recklessly causes bodily injury to another To Wit: Eoin Dwyer DOB: 12/25/2014, being 2 oem] Camo cok a See Aen [oss Oeese8 cafe |e [eee [ree 7 (se ig oeees por ST — a — a — ae Fempor bas” [a | Clsseyane Cl venzone (nalude te name af luis or rdnancoy RECKLESSLY ENDANGER ANOTHER PERSON ‘Acts of the accused associated with this Offense: PACC 2705 Recklessly endangering another person M-2 In that, on or about said date, the defendant, Courtney Stash DOB: 08/17/1989, did, as a principal and/or accomplice, recklessly engage in conduct which placed or may have placed Eoin Dwyer DOB: 12/24/2014, in danger of death or serious inchoate | [Attempt Solicitation Conspiracy bao [Oar _ [ose ores ole [ares Pa m0 1 dee 1 areata ce SRT —— eae — aa — RET CT mane ba [ee (if applicable) Number Disatety zone Dwiork zone alto Dosen (nluc the namo of lai o arnande): RECKLESSLY ENDANGER ANOTHER PERSON ‘Acts of the accused associated with this Offense: Criminal Conspiracy to Commit PACC 2705 Recklessly endangering another person - M2 In that, on or about said date, the defendant, Courtney Stash DOB: 08/17/1989, did conspire with Justin Dwyer DOB: (06/24/1988, to recklessly engage in conduct which placed or may have placed Eoin Dwyer DOB: 12/25/2014, in danger of AOPC 412A — Rev. 07/10 Page 7 of 23 :ras POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE Bock Wambo — [Dao Fe OFhvLNa8zan Naber laine umber fraosaes Datendentnane | Str as ca OFFENSE DESCRIPTION CONTINUATION Offense #1 : Dwyer DOB: 12/25/2014, in a reckless or grossly negligent manner, as a direct result of securing a mattress to the top of the victim's erib with a bungee cord, resulting in the victim's death by means of asphyxia, in violation of Section 2504 of the PA Crimes Code M-1 AOPC 412A — Rev. 07/10 Page 8 of 23pny POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE [ Docket Number: | Date File ‘OTNiLveScan Number Complaintincident Number | 17-0000263, Fist Tae | Last Defendant Name | COURTNEY | Stas OFFENSE DESCRIPTION CONTINUATION Offense #2 Dwyer DOB: 12/25/2014, in a reckless or grossly negligent manner, as @ direct result of securing a mattress to the top of the victim's crib with a bungee cord, resulting in the victim’s death by means of asphyxia, in violation of Section 2504 of the PA Crimes Code M-1. Page 9 of 23 ‘AOPC 412A — Rev. 07/10as POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE | ‘Docket Number: Date Filed: OTNiLiveScan Number Complaintiincident Number | Psendnttane | EStariey aad a OFFENSE DESCRIPTION CONTINUATION Offense #3 : person 18 years of age or older. To wit: The defendant did secure a mattress to the top of the victim, Eoin Dwyer's (DOB: 12/26/2014) crib with @ bungee cord, resulting in the victim's death by means of asphyxia. This act is in violation of section 2702 (a) (9) F1 AOPC 412A — Rev. 07/10 Page 10 of 23,es POLICE CRIMINAL COMPLAINT _ OFFENSE CONTINUATION PAGE Docket Number: | Date File ‘OTNiLiveScan Number ‘Complaintiincident Number 17-0000263 First ‘wide: Last: DefendantName | COURTNEY STASH OFFENSE DESCRIPTION CONTINUATION Offense #4 : years of age, by a person(s) 18 years of age or older. To wit: Courtney Stash and Justin Dwyer did secure @ mattress to the top of the victim, Eoin Diver's (DOB: 12/25/2074) crib, with a bungee cord, resulting n the victim's death by means of asphyxia. This acts in violation of section 2702 (a) (9) F-1 ‘AOPC 412A ~ Rev. 07/10 Page 11 of 23,as POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE Docket Numb Date File ‘OTNiLiveScan Number ‘Complaintincident Number ] 47-0000263 | First Tale: Last: DefendantName | COURTNEY STASH Offense #5 18 years of age or older. To wit: The defendant did secure a mattress to the top of the victim, Eoin Dwyer's (DOB: 12/25/2014) crib, with a bungee cord, resulting in the victim's death by means of asphyxia. This act is in violation of section 2702 (a) (9) F-2. ‘AOPC 412A — Rev. 07/10 OFFENSE DESCRIPTION CONTINUATION Page 12 of 23as POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE Dwetnine | ES it hs OFFENSE DESCRIPTION CONTINUATION Offense #6 ‘age, by a person 18 years of age or older. To wit: Courtney Stash and Justin Dwyer did secure a mattress to the top of the victim, Eoin Dwyer's (DOB: 12/25/2014) crib, with a bungee cord, resulting in the victim's death by means of asphyxia. This act is in violation of section 2702 (a) (9) F-2. AOPC 412A — Rev. 07/10 Page 13 of 23es POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE Docket Number: | Date Filed: ‘OTNiLiveScan Number ‘Complaintincident Number 117-0000263 First ‘wide: Last: DefendantName | COURTNEY STASH OFFENSE DESCRIPTION CONTINUATION Offense #7 In that on or about said date, the Defendant, Courtney Stash DOB: 08/17/1989, did, acting as a principal and/or accomplice, restrain another unlawfully in circumstances exposing him to risk of serious bodily injury. To wit: the defendant did secure a mattress to the top of her son, Eoin Dwyer's (DOB:12/25/2014) crib, with a bungee cord, causing Eoin’'s death by means of asphyxia, This act is in violation of section 2902 (c) (1) of the PA Crimes Code, Title 18 F-2 ‘AOPC 412A — Rev. 07/10 Page 14 of 232g POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE [ Docket Number: Date Fed: [rate ae Complainincident Number 17-0000263 [peteteninane | ESSerey Ee OFFENSE DESCRIPTION CONTINUATION Offense #8 : In that on or about said date, the Defendant, Courtney Stash DOB: 08/17/1989, did conspire with Justin Dwyer DOB: 06/24/1988, {o restrain another unlaw/lly in circumstances exposing him to risk of serious bodily injury. To wit: Couriney Stash and Justin Duyyer did secure a mattress to the top of their son, Eoin Duyyer's (DOB:12/25/2014) crib, with a bungee cord, causing Eoin’s death by means of asphyxia. This actis in violation of section 2802 (c) (1) of the PA Crimes Codo, Tite 18 F-2. ‘AOPC 412A — Page 15 of 23,as POLICE CRIMINAL COMPLAINT _OFFENSE CONTINUATION PAGE Docket Number: | Date File ‘OTNiLiveScan Number | ‘Complaint/incident Number ieee Cwatt | Ere a Sa OFFENSE DESCRIPTION CONTINUATION Offense #9 principal and/or accomplice, knowingly endanger the welfare of said child by violating a duty of care, protection or support, namely, by securing a mattress to the top of the victim, Eoin Dwyer's (DOB: 12/25/2014) erib, with a bungee cord, causing the victim's death by means of asphyxia, in violation of Section 4304(a) (1) of the PA Crimes Code. (18 P.S. 4304(a) a course of conduct of endangering the welfare of a child - Fel. 3rd) ‘AOPC 412A — Rev. 07/10 Page 16 of 23,es POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE ee ae a OFFENSE DESCRIPTION CONTINUATION Offense #11 misdemeanor of the 1st degree. °C 412A — Rev. 07/10 Page 18 of 23+s POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE Docket Number: | Date Filed: OTNiLiveScan Number Complainvincident Number 47-0000263 Fist Mice Last Defendant Name | COURTNEY STASH Offense #12: OFFENSE DESCRIPTION CONTINUATION misdemeanor of the 1st degree. ‘AOPC 412A — Rev. 07/10 Page 19 of 23,Psy POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE Docket Number: | Date Filed: ‘OTNiLiveScan Number ‘Complainvincident Number 17-0000263 First: Midler Last: Defendant Name | COURTNEY STASH OFFENSE DESCRIPTION CONTINUATION Offense #13: bodily injury by securing a mattress to the top of the victim's orib, with a bungee cord, resulting in the victim's death by means of asphyxia. This act is in violation of section 2705 of the PA Crimes Code, Title 18, M-2. ‘AOPC 412A — Rev. 07/10 Page 20 of 23,2s POLICE CRIMINAL COMPLAINT OFFENSE CONTINUATION PAGE Docket Number: | Date Fil ‘OTNiLiveScan Number ~ | Compiaintincident Number 17-0000263 First Wide Last DefendantName | COURTNEY ee OFFENSE DESCRIPTION CONTINUATION Offense #14: death or serious bodily injury by securing a mattress with a bungee cord to the top of the victim's crib, resulting in the victim's death by means of asphyxia, AOPC 412A — Rev. 07/10 Page 21 of 23Please provide the following Information for each co-defendant. seh Co-Defendant Data Sheet Docket Number: | Date Filed ‘OTNILiveScan Number ‘Complaintiincident Numbei 17-0000283 First ida: Last: DefendantName | COURTNEY STASH AOPC 412A ~ Rev. 07/10 Page 22 of 23ah POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: ‘OTNiLiveSean Number ‘Complainvincident Number 117-9000263 Fir Middle Tast COURTNEY | STASH Defendant Name l AFFIDAVIT of PROBABLE CAUSE Your affiants are Detective Todd J. Hirsch, Detective Brent Shultz, and Chief Detective Daniel Wright of the Lebanon County Detective Bureau, and Detective David Lauver of the North Lebanon Township Police Department On April 25, 2017, at approximately 0739 hours. NLPD and First Aid and Safety Patrol Ambulance Company were initially dispatched to a residence located at 185 Strack Drive Myerstown, (North Lebanon Twp), Lebanon County, Commonwealth of Pennsylvania, 17067, for a reported cardiac arrest involving a toddler. The initial responding officers and EMS personnel determined that the toddler was deceased upon arrival. NLPD officers then requested members of the Lebanon County Detective Bureau provide investigative assistance at the scene. At approximately 0815 hours, Affiants Hirsch, Shultz, and Wright responded to the residence on Strack Drive where we were met by NLPD Detective David Lauver. Preliminary investigation determined that two-year-old male toddler, named Eoin Dwyer DOB: 12/25/2014, had been found unresponsive and not breathing at approximately 0730 hours within his crib, located in the master bedroom, by his mother, Courtney Stash DOB: 08/17/1989. During the course of the initial investigation, Affiant Hirsch interviewed Courtney Stash, Eoin's biological mother. Stash told Affiant Hirsch that when she found her son, Eoin, he was standing/leaning and slumped over a top railing of his white in color crib. She said that |, DETECTIVE TODD HIRSCH , BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. (Signatur of Atfant) ‘Swotn to me and subscribed before me this day of Date , Magisterial District Judge My commission expires first Monday of January, AOPC 411 - Rev. 07/10 Page 1 of 4POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Docket Number: Date Filed: OTNLiveScan Number I [Gomplainuncident Number First DefendantName — |coURTNEY STASH Taide: Last AFFIDAVIT of PROBABLE CAUSE CONTINUATION he was unresponsive and not breathing at the time. Stash stated she immediately grabbed him and took him into the living room, where she performed CPR on him on the living room couch. On April 25, 2017, Affiants Lauver and Shultz interviewed Eoin's Step-Father, Justin Dwyer. Dwyer reported that he was asleep in the master bedroom at the time Eoin was discovered unresponsive and not breathing by Courtney Stash. Dwyer said he was awakened by Stash's screams after she discovered Eoin unresponsive in the crib. Justin Dwyer and Courtney Stash reported that they put Eoin to bed in his crib at approximately 2000 hours on April 24, 2017. On April 25, 2017, your affiants processed, documented, and photographed the residence as part of the child death investigation. The Lebanon County Coroner's Office also responded to the scene to pronounce Eoin Dwyer deceased and scheduled a forensic autopsy. On April 26, 2017, a forensic autopsy was performed on Eoin Dwyer at the Lehigh Valley Hospital in Allentown, Pennsylvania. Forensic Pathologist Barbara Bollinger, M.D. performed the autopsy. On April 28, 2017, Courtney Stash's oldest son, B. P., age 8, told Affiant Hirsch that his mother, Courtney Stash, and his stepfather, Justin Dwyer, routinely used a mattress that had a blue in color "Toy Story" theme bed sheet on it, to place on top of Eoin's crib. B. P. said the mattress was used by his parents to prevent Eoin from climbing out of his crib. B. P. indicated that this mattress had been used for at least a couple of weeks prior to Eoin's death. B. P, further reported, recently witnessing his mother and stepfather placing bags of suspected driveway salt which he described as “ice bags" on top of this mattress in an effort to further prevent Eoin from getting out of his crib. B. P. indicated that his mother and stepfather more recently began using a red in color rope/bungee cord, which he said had hooks on each end of it, to secure this mattress to the top of Eoin's crib for the purpose of preventing Eoin from climbing out of his crib. B. P. said Eoin was eventually able to push the mattress with the "ice bags" up, so they started using the rope/bungee cord to secure the mattress to the crib. (Gionature of Aint) AOPC 411¢ - Rev, 07/10 Page 2 of 4POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Docket Number: Date Filed ‘OTNiLiveScan Number ‘Complaintiincident Number 117-0000263 Defendant Name |6SurTNEY Stash ‘Middle ast AFFIDAVIT of PROBABLE CAUSE CONTINUATION During the initial scene assessment on April 25, 2017, your Affiants observed a mattress matching B. P.'s description in the master bedroom of the residence. The mattress was observed and photographed leaning up against the master bedroom bed. The location and positioning of the mattress did appear out of place to your affiants. During the initial interviews with Courtney Stash and Justin Dwyer, neither reported that any items had ever been used to cover and/or contain Eoin in his crib, prior to, or on the day that Eoin died (April 25, 2017). On April 28, 2017, Affiant Hirsch secured a search warrant for the residence located at 185 Strack Drive, Myerstown, PA, based on the information that was provided by B. P. During the search of the residence, Affiants Hirsch and Shultz located the blue "Toy Story” sheet/mattress, described by B. P., on top of the master bedroom bed. Affiants Hirsch and Shultz also located two 50 pound bags of ice melt driveway salt in the master bedroom closet. In addition, the red bungee style cord was also discovered, underneath the ice melt salt bags. These items all matched the description provided by B. P. The closet where the items were discovered was located only a few feet away from Eoin Dwyer's crib. Eoin's Dwyer's white crib, the twin size mattress with the "Toy Story" sheet, the bags of ice melt salt, and the red bungee cord were all seized as evidence. During the course of the investigation, Affiant Hirsch utilized the items that were seized as a result of the search warrant to recreate the scene as described by B. P. Upon closer inspection of Eoin's crib, Affiant Hirsch discovered numerous indentation/scuff marks that were consistent in both size and shape with the hooks from the red bungee cord. The hook marks were found on the bottom crib rails, on both ends of the crib, indicating the bungee cord had been used on multiple occasions. The twin mattress, the two 50 pound bags of ice melt salt, and the red bungee cord were all used during the demonstration and the process was documented by way of digital photographs. The bungee cord appeared to have been tied in a fixed position, which allowed for the quick set up and removal of the mattress to the crib. During a follow up interview with B. P. on May 05, 2017, B. P. indicated that he heard his mother and stepfather talking about how the mattress was "holding Eoin down on his neck so that he could not get out." B. P. said his mother and stepfather were having this (Signatur of ian’) AOPC 411€ ~ Rev. 07/10 Page 3 of 4POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE [Docket Number: | Date Filed: ‘OTNiLiveScan Number ‘Complaintiincident Number 7-0000263 Fist Defendant Name |CGuRTNEY Wide Last STASH AFFIDAVIT of PROBABLE CAUSE CONTINUATION discussion prior to the arrival of EMS and police on the morning of April 25, 2017. As a result of the autopsy and the investigative finding, Forensic Pathologist Bollinger opined with a reasonable degree of medical certainty that Eoin Dwyer's cause of death was "Asphyxia due to entrapment between crib and overlying twin mattress secured by bungee cording." In that your Affiants believe sufficient facts exist to substantiate the criminal violations enumerated within this criminal complaint and respectfully request Warrants of Arrest be issued for Courtney Stash and Justin Dwyer. AOPC 411¢ — Rev. 07/10 (Signature of Affant) Page 4 of 4