&
x3 POLICE CRIMINAL COMPLAINT
COMMONWEALTH OF PENNSYLVANIA Ps 4 COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: YORK _* oi . i
ToghiaiaavelNimber 10301 DEFENDANT:
Nou Nome: Hon JOHN, FISHEL “oot Lae THERNEY
here 2007 CAP HORN RO.
REDLON, PATTI, (FTES iow Tata am
[20 PERCHERON OR
‘Telephone: 717-244-4002 | YORK, PA 17406
| |
TEC ETA STION COURT
Felony Full Lys Feteny Pend. ~ [J e-atsdemeanor Sumounding States ‘Detance
IL] 2-Fetony tr, (18 Felony Pend. Extradition Ceterm, Clo misdameano: No Extradition
IC2] 2-Fetony Surrounding States. Cawistemeanor Full Clemisdemeanar Pending
1] 4-Felony No Ext Cs.mistemeanar Limited CD) Fittisdemeanor Pending Extradtion Deter.
SEFENDAIT DENTIFIGATION INFORMATION
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leesd si Name: icles Name: raat Name: jen.
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RACE, Bwnite Dp aian Ceiack, TD naive amencan Dv nknown
ETHNICITY To Hispanie Bd Non-Hispanic Dunkrawn
HAIRCOLOR —(] GRY (Gray) Ti) re0 (Red! Auda} — L) SOY (Sony) LJ BLU (Bue) Cpe crime) Bi ARO Mrown)
Deux Biack) Cleon (Orange) Chyna cries Foc quar, sas) EC} rw iGreen) Z] Pek qrinky
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EYE COLOR Dakar Chew wuey Bi) ar0 (Bonn) ‘Cars (Green) Dery Gay)
Dpaz criazet) Car (ntaroon) Denk inky Dom (atuticotoredy Bi x0x (unknown)
iver icense [State PA [lense numer 22464406 Eee WEIGHT 5)
[ona [Lives bao — [ova Lecaton
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[Dofondant Fingorprinted [CJ ves BIno. S 08
SEFENSANT VEHICLE FORMATION
Plate # | ‘State Registration Sticker (MMV) ‘Comm't Veh. Ind. ‘School Veh. th. NCIC Veh. Code
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VIN Year |Make | ‘Model jaa [Color
fica of he Atom ore Commarea Taare ose oan nome
|, TPR, JONATHAN COLARUSSO- ‘o9g263 1910273,
ot ag Panesar Stale Pole, Tigop tl. York PARSE
do hereby state: (check appropriate box)
1. accuse the above named defendant who lives atthe address set forth above
Gi accuse the defendant whose name is unknown to me but who is described es .
Gi accuse the defendant whese name and popular designation or nickname is unknown to me and whom | have therefore designated
as John Doe ar Jane Ooe.
ath violating he ena! inns of he Commonweath of Pensyvana st: 239... J. PERCHERON ORIVE., WINDSOR TOWNSHIP
in YORK_ Count 7 conor about 12/01/14 - 06
a Pha c209 Sree oontens
AOPC 412A-Rev. 12/44 Page 1 of 4Becket umbers | pao Fite: | oTWRiveScan Number Compainvincient Numbar
CKD 21S 1b IMAL 1 92018 19 3te 3 ie
Fist wise Last
Dotondant name | BS aE THERNEY
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 chronological
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sumer ease, yu mut te eect ete and suteetons) ha ates) eetorcesebgedy lated. Te apo ce vet ae tine fhe fons ay be re
‘oun. aden, soi secur mute and ancllomaton [2g Ps) should ol bested the ery ofa acu ust albedo dts, 204 PA Coe
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ae 1 |4304 | fad ofthe | Title 18 , PA Crimes Code 2 Fa 200/802
Oferse Seton Subenion PA Stat Te) Canis Giace_NCIG Oerse Gale UCRNERS Cate
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(appcabey numer | o7-2397664 Diteratte satay zone werk zone
‘Statute Description (include the name of statute or ordinance)
Endangering Welfare of Children
‘Acts of the accused associated with this Offense:
IN THAT, on or about said date(s), being a parent, guardian, or other person supervising the welfare of victims Stone
loyian HILL (DOB: 04/29/88) and Nicholas Alexander MANKIN (DOB: 08/14/88), children under the age of 18 years of age,
ITHE DEFENDANT did knowingly endanger the welfare of said children by violating a duty of care, protection or support, in
Wiolation of Section 4304(a) of the PA Crimes Code. TO WIT: THE DEFENDANT knowingly endangered the welfare of the
fclims HILL and MANKIN by harboring or condoning an environment where illegal activity such as underage drinking was
[permitted or tolerated, and where the vietims knew they could consume alcohol at THE DEFENDANT'S residence without
tear of reperoussion, and in fact did so, THE DEFENDANT'S repeated violations of duty to care, protect, or support,
lculminated by his/her failure to intervene or to ensure that intoxicated minors at his/her residence did not operate a motor
lehicl, uitimately caused HILL and MANKIN to die in a single motor vehicle crash
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appcable numer | 07 os97a54 Climeratte Cisatey 2000 Cwerczone
Statute Description (include the name of statute or ordinance)
Involuntary Manslaughter
‘Acts of the accused associated with this Offense:
IN THAT, on of about said date, THE DEFENDANT did engage in the doing of an unlawful act in a reckless or grossly
Ineglgent manner, or the doing of a lawful actin a reckless or grossly negligent manner, in which she caused the death of
lancther person, namely victims Stone Dyllan HILL (DOB: 04/29/88) and Nicholas Alexander MANKIN (DOB: 08/14/88), in
Jiclation of Section 2604(a) of the PA Crimes Code. TO WIT: THE DEFENDANT was reckless or grossly negligent in allowing
Iminors to regutarly consume alcohol at his her residence, then failed to prevent intoxicated minors at his/her residence from
loperating a motor vehice, which caused the deaths of victims HILL and MANKIN who died due to an alcohol related, single
lmotor vehicle crash.
AOPC 412A - Rev. 12/14 Page 2 of 4.ag POLICE CRIMINAL COMPLAINT
Docket Number: Date Filed: | OTN/LIveScan Number Complaintincident Number
H7-2401691
T1946 380-
CR. 6215-1 La [MAY 19. 20
bafendant Name | FER [ite “bee
‘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.
‘BE nor sonnay ot ase sear noes eStore at Ose) carges Actua the alte) sgtly waa ANE a ol us m8
rary ca, you mut cee speci ecg) a subsectors) tba ses) or caret] lage Wobted,Th age he vic tate ot oftese nay be nao
ci In séten, sca secary mars a aidan (eg PINS) shal nat ses Haley oan ecaun ustba ebsod ese tr igs 204 PA ode
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at 3 [6301 | end, ottne_| Title 18, PA Crimes Code 4 M1 260/002
‘ene Secon Svbsecion PA Ste TH) ‘Coins Gree NOI Ofer Goto UGRNTERS case
PennDOT Oa Tet
ae Number | no7-2307654 Diineratate Ci satay 200 wer zone
Statute Description (include the name of statute or ordinance)
Corruption of Minors
‘cls of the accused associated with this Offense:
IN THAT, on or about said date, THE DEFENDANT, except as provided in subparagraph (i), whoever, being of the age of
18 years and upwards, by any act corrupted or tends to corrupt the morals of any minor less than 18 years of age, or who
jaided, abetted, enticed, or encouraged any such minor in the commission of any crime, ot who knowingly assisted or
lencouraged such minor in violating his or her parole or any order of court, commits a misdemeanor of the frst degree. TO
WIT: THE DEFENDANT corrupted the morals of minors Stone Dyllan HILL (DOB: 04/29/88), Nicholas Alexander MANKIN
(008: 08/14/88), minor D.N.G (DOB: 02/01/98) and minor C.M.H (DOB: 08/24/97) by purchasing and furnishing alcohol to
|minors, and also allowing minors to engage in the consumption of alcohol between the aforementioned dates.
inchoate Tate [] Saistaton Conspiracy
tense 105054 189024 19900
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tea 4 [6310.1 |i) ctne [Title 18, PACrimesCode [1 _ | m3 2201906
Ofensen __Secton_Subeedion PA Saute (ie) Gears Grade NCIC OFense Cede UCRIIBRS Cote
PonaDoT Ose “eset
een orter | H07-2307064 Citeratato Disatey zone work zone
Statute Description (include the name of statute or ordinance):
Selling or Furnishing Liquor or Malt or Brewed Beverages to Minors
‘Acts of the accused associated with this Offense:
IN THAT, on or about said date, THE DEFENDANT di intentionally and knowingly sell or intentionally and knowingly
lurnish, or purchase with intent to sel or furnish, liquor or malt or brewed beverages, namely, "Redds Apple Ale," "Reds
|Strawberry Ale." "Bud Light” beer, "Busch" beer, and “Four Loko" peach alcoholic beverages, to minors Stone Dyllan HILL
(DOB: 04/29/88), Nicholas Alexander MANKIN (DOB: 08/44/88), minor 0.N.G (DOB: 02/01/98), minor N.D.A (DOB:
13/08/99), and minor C.M.H (DOB: 06/24/97) who were less than 21 years of age, in violation of Section 6310.1(a) of the PA
fimes Code,
Page 3 of 1
AOPC 412A - Rev. 12/44das POLICE CRIMINAL COMPLAINT
| Docket Numbor: Date Filed: OTNiLiveScan Number Complaint/incident Number
Ce szieil| mT Sao 114 L38lo-3 ae
Fist idle Last
2. ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the
charges I have made,
3. | 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 01_ through 04
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.)
Covarssso,S (027?
AND NOW, on this date, ——tceftify that the complaint has beempgpeHy”,
completed and verified, An affidavit of probable cauge musi-be Completed before a warrant. teat BENE,
AOPC 412A - Rev. 12/14 Page 4 of 4: deh ___ POLICE CRIMINAL COMPLAINT
oa Rarer: | ba Hig] OTILIveBean ama
‘Gomplainvincident Number
Ah, O21S) bs, MY 19 20M Db A8L-3. H7-2401691
First Middle: Last
[Botendant name: | JODIE LYNNE TIERNEY
AFFIDAVIT of PROBABLE CAUSE
Your affiant is a Pennsylvania State Trooper currently assigned to the Criminal Investigation Unit, Troop H
York Station. | have been employed with the Pennsylvania State Police since December 12", 2005, and have
been assigned to the CIU since October, 2041. In that time, | have been the primary and secondary
investigator for a wide variety of criminal cases that have resulted in successful prosecution including but not
limited to homicides, attempted homicides, robberies, sexual and physical assaults, burglaries, firearms act
violations, fraud, political corruption and prosecutable fatal crash investigations. As of January 17", 2014, your
affiant received Class A Wiretap certification pursuant to the provisions of Chapter 67, Title 18 which, in part,
authorizes your affiant to monitor and intercept wire, electronic, and oral communications.
On 06/16/18 at approximately 1910 hours, Troopers from the Pennsylvania State Police, Troop H York
Barrack were dispatched to Slab Road west of Thompson Road, Lower Chanceford Township, York County,
Pennsylvania for a reported one vehicle crash. Trooper Evan BUEHRER was assigned as the primary
investigator. The initial crash investigation determined that a 2002 Toyota 4-Runner ‘SUV was traveling east on
Slab Road at a high rate of speed before the operator lost control. The vehicle struck a utility pole and
overturned. The driver of the SUV was identified as 17 year old victim Stone D. HILL (DOB: 04/29/98). The
front seat passenger was identified as 16 year old victim Nicholas A. MANKIN (DOB: 08/4 4/98). Both HILL and
MANKIN were pronounced dead at the scene. The York County Coroner's Office ruled the cause of death for
both individuals as multiple blunt force trauma. The manner of death for HILL and MANKIN was ruled
accidental due to a single motor vehicle crash.
A toxicology analysis was performed on the blood of vehicle operator Stone HILL by the Pennsylvania
Department of Health Bureau of Laboratories. The final analysis was completed on 07/13/15. The analysis
indicates HILL'S blood alcohol concentration was .094% at the time of the fatal crash. No drugs of abuse were
detected.
-CONTINUED-
1, TPR. JONATHAN COLARUSSO, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT
THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT 1 THE BEST OF MY
KNOWLEDGE, INFORMATION AND BELIEF.
(Ghana of Aan
‘Sworn to me and subscribed before me this
Date
My commission expites first Moped of January,
SEA
ny. pists
fea
“AOPC atic Rev. 07/10dee POLICE CRIMINAL COMPLAINT
AFFIDAVIT CONTINUATION PAGE
eee a Fig ay se imber:
D2 I be Td le Z&le
Dotendantname: | Sobhe SNe |
AFFIDAVIT of PROBABLE CAUSE CONTINUATION
The crash was later reconstructed by Corporal Andrew THIERWECHTER of the Pennsylvania State Police
Collision Analysis and Reconstruction Specialist (CARS) unit. The following conclusions were reached by
Corporal THIERWECHTER during the course of the investigation based on the available information and the
existing science and accepted practices in the field of collision reconstruction:
1, Unit #1, a 2002 Toyota 4-Runner was traveling east on 1793, Slab Road
2. Unit #1 was reportedly driven by Stone D. HILL.
3. Control loss occurred prior to Unit #1 entering the left curve that it was approaching and just as it was
beginning to descend the hill it encountered
4, Unit #1 was positioned in the center of the roadway at the onset of control loss.
8. Unit #1 was traveling between 64 and 73 mph at the point of control loss.
6. The ctitical speed of the curve that Unit #1 was approaching is 78 mph.
7. The operator of Unit #1 lost control as a result of excessive steering for the speed traveled, exacerbated
by alcohol impairment of the operator.
8. Toxicology results indicate a BAC of 0.094% wiv for operator HILL.
9. There is no evidence of mechanical defect or failure,
10. There is no evidence to suggest another vehicle was involved, either by contact or proximity
11. Stone D. HILL and Nicolas A. MANKIN died of multiple blunt force trauma resulting from the collision
In the days following the fatal crash, PSP received information from the public which suggested that HILL.
and MANKIN were consuming alcohol at the residence of defendants Jodie Lynne TIERNEY and Stephen
Douglas TIERNEY (80 Percheron Dr., Windsor Township) prior to the fatal crash and that the defendants were
knowledgeable that minors regularly consumed alcohol at the residence. it was also suggested that social
media evidence had been disseminated by the victims prior to the crash which corroborate the underage
drinking. As a result of this allegation, a criminal investigation was initiated which has been ongoing for
approximately 11 months.
The defendants, Jodie Lynne TIERNEY and Stephen Douglas TIERNEY are husband and wife who currently
reside at 80 Percheron Drive, Windsor Township, York County. The defendants were residents of this address
between December 1° 2014 through June 16", 2015 and also reportedly owned a residence in Adams
County, Pennsylvania, which has specific relevance to this investigation. The defendants have two children,
both of whom are under the age of eighteen and were acquaintances of victims HILL and MANKIN,
-CONTINUED-
(Signatue of Affant)
“Rope 411C - Rev. 07/10dees POLICE CRIMINAL COMPLAINT
AFFIDAVIT CONTINUATION PAGE
Pes Number: Date Filed: 1 OTNiLiveScan Number: ‘Compainineldent Number
Fe bLIE-1le MAY 1-9 201 719 Bho nreeie
ay Fist ‘dale Last
defendant Name: | JODIE LYNNE TIERNEY
AFFIDAVIT of PROBABLE CAUSE CONTINUATION
At the onset of this investigation, video and photographic evidence was obtained from the ‘Snapchat social
media accounts of victims HILL and MANKIN. On the date of the fatal crash (06/16/15), a video file was posted
by HILL to his own account or “story” which depicted HILL holding a bottle of Bacardi rum, then consuming a
clear liquid from a standard shot glass. Similarly, a still-frame photograph posted to MANKIN'S Snapchat
account on the day of the crash depicts MANKIN and other confirmed minors socializing in a kitchen/lving
room of a home while possessing and in close proximity to various types of suspected beer and liquor. The
‘other minors depicted in the above described media were positively identified and will hereafter be referenced
in this document as C.M.H, (DOB: 06/24/97) and N.D.A (DOB: 03/08/99). CMH and other witnesses familiar
with the defendants’ household were interviewed during the course of this investigation and confirmed the
aforementioned video and photographic image were taken inside of the defendants’ residence the day of the
fatal crash.
PSP also obtained content from the Instagram social media account of a juvenile identified as K.B.0. (DOB:
09/12/97). On the night of Stone HILL'S viewing, KBO was with several other minors at the defendant's home,
KBO posted photographs of himself online where he appeared to be drinking directly from a bottle of fiquor
inside the defendant's residence. A caption from an associated picture reads, “At (Jodie TIERNEY'S] house
without [Jodie TIERNEY'S son] drinking his mom's alcohol.” KBO was later interviewed and authenticated the
photos. He stated he was in possession of a bottle of liquor at the defendant's home the night of HILL'S
funeral, and posted Instagram photos and comments to the same effect. KBO explained that he was only
pretending to chug from the bottle, and denied consuming any alcohol that night.
‘On 08/06/15, | interviewed juvenile B.J.H. (DOB: 06/21/98) at the PSP York Station, BJH related that he is
familiar with the defendant's home and admitted to drinking alcohol at the residence on multiple occasions
between January 2015 — June 2015. He advised that defendant Jodie TIERNEY purchased alcohol for the
minors on at least one occasion he was aware of. BJH said on at least 3-4 occasions, defendant Jodie
TIERNEY came down to the basement to check on the minors, which included HILL and MANKIN. He said
when defendant Jodie TIERNEY came down to the basement, all of the minors were actively and obviously
engaging in underage drinking of alcohol in the defendant's presence. BJH said defendant Jodie TIERNEY
never stopped them or reprimanded them. He related that she was “coo!” with them drinking alcohol in the
basement. BJH further advised that the defendant never requested that anyone give up their car keys and
never required any of the kids to spend the night if they were drinking
‘On 08/25/18, CMH was interviewed at the PSP York Station. CMH related that numerous minors (Including
victims HILL and MANKIN) would regularly drink alcohol underage at the defendants’ home without fear of
repercussion or consequence, and indicated that the defendants were knowledgeable of their actions and
condoned the behavior. As evidence to this claim, CMH cited several occasions where defendant Jodie
TIERNEY purchased alcohol for minors to consume. One of the occasions cited by CMH allegedly occurred
‘over the Mother's Day weekend of 2015 (Saturday May 9” — Sunday May 10", 2015). CMH stated that
defendant Jodie TIERNEY purchased a 12 pack of Redd’s Apple Ale alcoholic beverages and fast food for
assisting her with landscaping work. CMH said he and MANKIN consumed the alcoholic beverages along with
minors including but not limited to NDA, and D.N.G. (DOB: 02/01/98).
-CONTINUED-
(Signatuce of Aint)
‘APC 4116 - Rev. 07110 Page 3 ofdas POLICE CRIMINAL COMPLAINT
¢ AFFIDAVIT CONTINUATION PAGE
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AFFIDAVIT of PROBABLE CAUSE CONTINUATION
‘A Facebook post from defendant Jodie TIERNEY’S account dated 06/09/15 was obtained during the course
of this investigation. In the post, the defendant thanked several minors including MANKIN, NDA, and CMH for
performing landscaping work al her home. Commenting on the same post, the defendant wrote that the minors
“work for food and drinks.”
CMH further related defendant Jodie TIERNEY purchased a case of Bud Light beer for minors after dining at
a restaurant in Adams County, PA in April of 2015. During this investigation, a photograph was obtained from
the Apple ICloud account of victim Stone HILL. The photograph, which was attached to a text message
conversation, depicted defendant Stephen TIERNEY posing with his two sons, and four other minors while his
oldest son, identified as $.0.T (DOB: 12/28/98), was in possession of an apparent case of Bud Light beer.
CMH, who himself was depicted in the photograph, authenticated the image as an accurate representation of
the aforementioned alcohol purchase made by Jodie TIERNEY in Adams County. He further indicated that
defendant Jodie TIERNEY was responsible for taking the photograph. CMH positively identified the other
minors in the photograph as C.M.S. (DOB: 09/11/98), NDA, and DNG, CMH related that the minors consumed
the alcohol that evening while the defendants were present. The text conversation containing said photo was
dated 04/20/16 and included messages between Stone HILL, Nicholas MANKIN, DNG, CMH, and SDT. in the
body of the text message conversation, the minors imply their intentions to drink alcohol at the defendants’
residence on the last day of school. SDT (the defendants’ son) stated, "I'm down with hanging out. | just can't
drink anymore because | had a nice chat with mamma and papa joined about all that.” MANKIN responded
that he spoke with both defendants, who said they (the defendants) were much more comfortable with the
minors drinking at their home “instead of going out to parties.” SDT then states, "Okay. I'l ask my parents. |
have to clean the basement still from last Friday lmao.”
CMH also admitted to consuming alcohol at the defendants’ residence on Monday night 06/15/15 while the
defendants were home, and during the day on 06/16/15 when the defendants were not home, At least ten (10)
minors were identified as individuals who consumed alcohol Monday night into Tuesday. CMH confirmed both
HILL and MANKIN consumed multiple alcoholic beverages at the defendants’ residence during the morning
and afternoon hours the day of the fatal crash. He also reported that some of the alcohol consumed (including
the bottle of Bacardi rum referenced above) was obtained from the defendants’ liquor cabinet. Additionally,
‘CMH reported that NDA consumed nearly an entire bottle of liquor the day of the fatal crash, which he says
was obtained from the defendants’ home. CMH described that NDA became extremely ill from ingesting
alcohol throughout the day to the extent that he vomited and passed out in a bedroom. CMH estimated that
between 1700-1800 hours, NDA's father arrived at the defendant's residence to take custody of his son.
NDA's father learned that his son was severely intoxicated. CMH reported witnessing a conversation between
both defendants and NOA's father where they spoke of their embarrassment that NDA had become sick as the
result of consuming alcohol throughout the day at the defendants’ home. It was reported that NDA was so
drunk that he was unable to walk under his own power and had to be carried to his father’s car by HILL and
MANKIN.
-CONTINUED-
_ate,
(Signature of Affant)
“AOPG 4116 - Rev. 07/10
Page 4 of fei POLICE CRIMINAL COMPLAINT
AFFIDAVIT CONTINUATION PAGE.
‘Complaindineléent Number
[ Dgeket Number: —] Date Filed: | OTNiLiveSean Number: z
, W18 ‘2018. T 79 b 2eb- 172401681
i Mid: task
ee [ite ey
AFFIDAVIT of PROBABLE CAUSE CONTINUATION
‘Additionally, CMH alleged the defendants participated! in cleaning up the beer cans, bottles, and associated
{rash that had been left upstairs by the minors throughout the day. CMH indicated the defendants were
concerned of emergency responders arriving at the residence based on NDAs condition, and potentially
discovering evidence of minors consuming alcohol. CMH further indicated that HILL had a conversation with
defendant Jodie TIERNEY and apologized prior to driving away. Even when presented with the events and
circumstances described by CMH, no actions were taken by the defendants to prevent HILL, or any other
minor at the residence during the day, from operating a motor vehicle.
Carol TRACEY (Nicholas MANKIN'S mother) reported having a conversation with defendant Jodie TIERNEY
several days after the fatal crash. In the conversation, TRACEY said defendant Jodie TIERNEY described her
knowledge of what occurred on 06/18/15 prior to the fatal crash, but excluded any mention of minors
consuming alcohol. However, TRACEY recalled Jodie TIERNEY specifically mentioning that she (Jodie
TIERNEY) found minor NDA lying face down in one of the beds covered in vomit.
On 09/03/18, DNG, a minor who was present at the defendant's home the evening of 06/16/15 prior to the
fatal crash, was interviewed. ONG confirmed that minors, including victims HILL and MANKIN, would
frequently drink aicohol underage at the defendant's residence without fear of repercussion or consequence.
DNG admitted to drinking underage at the defendant's home on multiple occasions between December 2014 ~
June 2015. He recalled an incident in December of 2014 where he and other minors were drinking beer in the
basement of the defendant's home when they were encountered by defendant Jodie TIERNEY. ONG advised
that defendant Jodie TIERNEY admonished them about drinking aicohol on this occasion, but never contacted
their parents. It was described that the underage drinking parties at the defendant's home developed further
after this event. DNG advised that a few months later, minors began asking Jodie TIERNEY to purchase
alcohol for them. He recalled a specific occasion in 2015 where Jodie TIERNEY purchased alcohol at Cape
Horn Beverage in Red Lion for HILL, MANKIN, DNG, NDA, SDT, and other minors. DNG said MANKIN
approached Jodie TIERNEY, and asked her to buy alcohol. She agreed, and DNG said the minors “pooled
their money together" which was then provided to Jodie TIERNEY to purchase alcohol. DNG stated Jodie
TIERNEY then drove a group of minors to Cape Horn Beverage and bought them cases of known alcoholic
beverage consisting of Redd's Ale, Busch beer, and "Four Loko.” DNG said they retumed to the defendants’
home and consumed the alcohol. He stated Jodie TIERNEY drank alcohol with the group of minors on this
occasion. Furthermore, DNG confirmed CMH's statement regarding Jodie TIERNEY purchasing Redd’s Apple
Ale for minors on Mother's Day weekend, 2016.
-CONTINUED-
‘Signatur of Affantdees POLICE CRIMINAL COMPLAINT
3 AFFIDAVIT CONTINUATION PAGE
Date Filed: [ OTNILiveScan Number: omplainvincidentRumber
Mm T7196 286-3 H7-2401691
Fist iat ast
Deronaent Name! JODIE LYNNE: TIERNEY
AFFIDAVIT of PROBABLE CAUSE CONTINUATION
‘On 09/16/15, | made contact with Dave VANZANT, store owner of Cape Horn Beverage in Red Lion, PA.
Upon speaking with VANZANT, | requested any transaction records associated with the defendants prior to
06/16/15. In response, VANZANT provided records indicating that Jodie TIERNEY made purchases of
alcoholic beverages consistent with the statements provided by CMH and DNG. Specifically, a transaction in
Jodie TIERNEY’S name was compieted on 04/02/15 where she purchased a 12 pack of Redds Strawberry
Ale, a 30 pack of Busch beer, and 12 cans of Four Loko peach alcoholic beverages. Your affiant found this,
transaction to be consistent with the statement provided by DNG. Of additional note, defendant Jodie
TIERNEY used $100 cash for a portion of the transaction (consistent with the claim that minors "pooled their
money together’) and completed the remainder of the transaction with her credit card, Furthermore, a
transaction record existed for 05/09/15 where defendant Jodie TIERNEY used her credit card to purchase a 12
pack of "Redds summer variety" alcoholic beverages, also consistent with the statements of CMH and DNG.
During the investigation, further interviews were conducted with minors identified as CLG (DOB: 10/18/99),
AML (DOB: 10/25/99), and JBG (DOB: 10/26/97). In short, CLG, AML, and JBG all admitted to drinking at
underage parties at the defendants’ home prior to the June 2016 fatal crash. It was reported that underage
drinking parties were held at the defendants’ residence where, at times, ten or more minors would be
consuming alcohol at varying locations both inside and outside of the residence while the defendants were
home. This was the case on 06/15/15, the evening prior to the fatal crash. It was also reported that beer cans,
alcohol bottles, and trash associated with these parties were offen left out in plain view and not cleaned up
until the morning.
Each juvenile listed in this affidavit was interviewed with their parents present. In every circumstance, the
parents reported being unaware of the underage drinking allegations at the defendants’ residence prior to the
fatal crash. The victims’ parents (Glenn/Tina HILL & Bryan/Carol TRACEY) reported that if they had been
made aware of the circumstances concerning alcohol consumption at the defendants’ residence, they would
not have permitted their sons to visitor to be under the defendants’ care or supervision. Furthermore, the
parents of Stone HILL and Nicholas MANKIN were under the impression that their children were under the
direct supervision of at least one of the defendants the date of the fatal crash.
The information contained within this affidavit is not all that is known to your affiant, but only that which is,
necessary to establish probable cause for the charges contained in the preceding criminal complaint.
The charges contained in the criminal complaint were approved by York County Assistant District Attorney
Timothy J. BARKER.
The defendant has not been fingerprinted,
‘Your affiant believes the above information to be true and correct to the best of my knowledge and belief,
and respectfully requests the initiation of due process for the defendant.
(signature of Ant)
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