hes POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTNfLiveScan Number: Complaintilncident Number (Lg/3193,11? amen? 853 Puss)? PMS-1211823 First: Middle: Last: Dafendant Name: Linda NOLAN AFFIDAVIT of PROBABLE CAUSE l. your af?ant, am a Member of the State Police currently assigned to Troop Chambersburg. Criminal Investigative Unit. During my career as a State Trooper, i have investigated several different crimes that include but not limited to homicides. suicides. physicai assaults, sexual assauits. and crimes against Children. On 10/19/18 I was dispatched to Miracle Bush Learning Center located at 9540 Molly Pitcher Highway. Southampton Twp. Franklin County. This building is described as a yeilow singie story building with doors on the front south corner and north corner. There is a ptayground in the back with a black fence around it. Their hours of operation is 0530 until 1800 hours however some Chiidren arrived as eariy as 0345 hours. The ages of the children varied from infant to seven years of age. The original dispatch was related to the owner, Michael NOLAN. as ressively, physically pushing out of the at the scene who related that there have been ongoing issues with the daycare pertaining to Michael and Linda NOLAN (owners of Miracie Bush) and their treatment of staff and children. On 10/26/18 I spoke with at station. She worked at Miracle Bush from September 24. 2018 until October 19, 2018. asked her what occurred on 10I19I18. She related that severai staff members came to her with concerns about the way that Michael and Linda NOLAN were treating the Children. They ail decided that they were going to quit. She waited to leave until all the other staff members gathered their belongings. When Michael saw what was happening he started to berate her and toid her that she needed to teave. She informed him that she was going to leave once everyone else got their belongings. Michael proceed to grab her by the shoulders and aggressively push her towards the door. Once they were at the door, he gave her a violent shove out of the door. She reiated that she tensed up her back and leg muscles to keep from faliing. Because if this, she reiated that she was sore. She proceeded to her vehicle and waited untii the other staff members exited the building. Michael came towards her vehicle. She was able to lock the doorjust before he attempted to open the door and demanded that she get out. Once he saw that she was on the phone. he retreated into the building. She related that this was in front of the Children. Continue 1, TPR. LINDSEY TRACE, 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. i CERTIFY THAT THIS COMPLIES WITH THE PROVISIONS OF THE CASE RECORDS PUBLIC ACCESS POLICY OF THE UNIFIED JUDICIAL SYSTEM OF THAT REQUIRE FILING AND DOCUMENTS DIFFERENTLY THAN NON-CONFIDENTIAL INFORMATION AND CUMENTS. (Signature of Af?ant) Sworn to me and subscribed before me this 3 :5 day of Mfr/19M 526/ 2 0/57 Date Magisterial District Judge My commission expires first Monday of January, 2 0 mam.? M-W. .. 4? - p. AOPC 411C Rev. 07/18 I Page 1 of POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Docket Number: Date Filed: OTNlLiveScan Number: f. Number 3423a! Neon 3/ I953 tugs; First: Middle: Last: Defendant Name. Linda NOLAN AFFIDAVIT of PROBABLE CAUSE CONTINUATION further related that In her short time working there she observed several things that gave her great concern She explained that Linda and Michael would yell and scream at the kids. She described that kids were put in ?bucket seats" for long periods of time for punishment Bucket seats were explained as plastic seats that sit into a table They have a belt to restrain the kids from getting up or falling. Linda would put kids In these seats if she "couldnt control them" Linda would also withhold their snack from them for being "bad." Linda and Michael thought that kids were born to behave and if kids were ornery or "just being kids? they were considered bad and they were punished. Michael and Linda would both put kids In the bucket seats for punishment also related that one time she was in the of?ce and needed Michael to look at something on the computer. While they were lookIng at the computer Michael started to run his hand up her Inner thigh towards her waist/vagIna He left his hand resting on her inner thigh This was unwanted contact. She had to move her body in several different ways for him to remove ills hand from her innerthigh. On 10/31/18 I interviewed She related that she had concerns about what was going on at the daycare. She gave me an example that there was a two- year-old girl that was left In the bucket seats all day. asked her what all day consisted of. She related that this girl would spend 5 hours In the bucket seats. if the staff took any of the kids out of the bucket seats. Linda would berate them (staff) and yell at the kids and put them back' In the seats. She stated. "they had to strap kids In with like a seat belt so they couldn? get out. i asked her what age group of kids would be appropriate for the bucket seats. She explained that two- -years of age would be the oldest that should be In there However some of the two-year-old children were big for their age and they should not have been in the bucket seat She related that 'the seat. was not able to swing her legs or move at all while in this seat. explained that on 10119/18 she was in the front room with the older kids for most of the day. Linda took their morning snack away from them. There was a three-year?old boy who Was out of his seat. Linda came out from the of?ce and g'rabbed him by the upper arms and tossed him into his chair. The Chair rocked. She was behind him and she was still holding his arms and she shook him and his head snapped back and forth. He started crying. She got in his face and started yelling, ?why can ?t you sit down? Why can?t you listen? What's wrong with you?? She related that Linda shook him two or three times and described it as "forceful.? was "sobbing" after this happened and she could tell that he was scared. ?related that the same day, a ?ve?year-old boy (. would not lay on his nap mat. Michael came out of the kitchen grabbed by the hood and pulled him off of his mat and across Ine carpet. He took his mat from him and made him stand for the remainder or nap time. She told what had happened and they decided that they needed to quit She related that she saw Michael grab . . by the shoulders and he "threw? her out the front door. askedwwhat a normal day was like there. She related that Linda would leave the kids with the assistant teachers even though they did not meet the criteria to be left alone with the children. Linda would tell them not to tell anyone that they were being left alone with the kids. Linda would never allow the children to go outside. Linda would make the kids sit for hours in the morning with nothing to do. They would eat lunch around 1130 and then have quiet time for two hours. After quiet time was supposed to be bathroom time. She stated, "she (Linda) treated that like a privilege. There were two of them that were pull ups and if they weren't quiet during nap time. she would make them sit in their pull up for two or three hours even if they were wet." Linda knew that the kids needed changed. Linda would feel their pull up and say, "well you weren't quiet, so now you have to sit in it.? The staff would ask to change the children. Linda would tell them. "well I'm your boss and I told you no.? said that a punishment that Linda would give to the kids was making sit at the table with their heads down. She recalled all of the preschool children having to sit there with their head down from 1430 hours until 1800 hours. Wrz?ffg?b (Signature of Affiant) AOPC 4110 Rev. 07MB I Page?: POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Docket Number: Date Filed: OTNlLiveScan Number: I Complainmncident Number (3,3419in tr logger?In? . First: Middle: Last: Defendant Name: Linda NOLAN AFFIDAVIT of PROBABLE CAUSE CONTINUATION - related that one time one of the kids was rocking his chair on tWo legs. Linda came behind him and up ended it with him still In the chair. She then made the children Stand. She remembers one child three-year?oid having to stand for an hour and a half. if he would move to shift his weight Linda would add time. ?described Michael and Linda ?mean aggressive? 'with the kids. She stated "i saw Mike put his hands on kids more." She described that Michael would grab kids to put them back in their chair or grab kids to move them i asked about kids in bucket seat. She related that there was a two-year?oid boy who was in the bucket seat for seven or eight hours. azday. .This was seven or eight hours straight with no play time or breaks. He Was only allowed out of the seat to be changed if it started to stink (poop). Nobody would be allowed to check to see it he had wet his pants. The staff was instructed by Linda to get him out of the seat 15 minutes prior to his parents picking him up and put crayons in front of him to "pretend he wasn't in the bucket since he got there." She also related that this boy is too big for the bucket seat. but he was still forced to sit there all day. - also mentioned that was in the bucket seat for ?ve hours She related that was buckied into the seat for the whoie 5 hours so that she could not get out. agreed that these children were ?beaten into submission.? Without hesitation she stated, "yes. They are terri?ed of her. i am terri?ed of her. They listen to her because they know that something bed will happen if they don?t.? related that kids' In the bucket seat would just scream until they tired themselves out or heir was broken. 6? I ?I'm-55? On interviewed at PSP Chambersburg. She was the -. at Miracle Bush. She started to work at Miracle Bush in May of 2018 and quit in August of 2018. She related that Linda and Michael would yell and scream at the kids. Examples that she could think of were, "You don't listen? ?Sit down. .What have i been telling you? I can ?t take this. .Shut up She described it as ?college talk." This occurred during the whole time she was employed there and was said numerous kids. '2 - related that the kids would sit at tables all day without anything to do. Linda would only allow the kids to have one- bathroom trip during this time 2 described that one time she was in the back room and could hear '.?thuds She was informed that Linda was in the bathroom with one of the children. -- was not sure what was going on until one day she walked past the bathroom and saw Linda grabI ?ve-year-oid boy by the upper arm and drag him into the bathroom. She described that Linda. "picked him up and stuck him against the Wall She was nose to nose with him screaming ?you are not going to act like this. i told you before. Li a to?i?? her . 2i a?en?onf and other staff members to pull girls? pony tails because "it does not leave marks and it gets their - aiso related that there was a two year- -old girl .that Linda did not like when she moved on her nap mat. There were numerous times whit as employed there that Linda would grab her by the collar and back of her pants and' slammed? her on her mat on her beliy and took her hand and held her head down on the mat. Linda would state. Is when you have to show them who the boss Is." con?rmed what the other staff members had mentioned about the use of bucket seats for punishment and the length In which they were in there. related that there was a child with diagnosed autism When she would have her ?tits Linda would 'restrain' her In a high chair Linda stated going to leave her here until she learns She would be In the highchair from 1330 hours until 1700 hours. W775 Xb (Signature of Affiant) AOPC 4110 Rev. ems I Page er_ POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION Docket Number: Date Fited: OTNtLiveScan Number: Complainttincident Number Cut!? Man I Insane I953 6H3w I PA18-1211823 First: Middle: Last: Dafendant Name. Linda NOLAN AFFIDAVIT of PROBABLE CAUSE CONTINUATION On 11/21/18 I spoke with Bush in 2016 and stopped attending in August of 2017. Durin- because Linda wouid withhold his snack for punishment. =27; . . out. who is a parent to a chiid that used to go to Miracle Bush. Her son. I . attended Miracle the time that he attended Miracle Bush was always hungry reported that was put in a high cnasr and was not aiiowed to get A CAC interview was held for . During the CAC interview he stated "a man puiled me by my hood. He identified the ?man? and Michael NOLAN He related that he was pulled by his hood because he was rolling around on his mat. He further described the incident by stating. was getting dragged On 11/14/18 1 spoke with She is the grandmother of and was an employee of Miracle Bush The week after the 102'19/18 incident Miracle Bush closed. Linda asked to work we mornings for her to help with ratios. During the week that Mi to Bush was closed. Linda askea . to store a table with bucket seats andi ?ling cabinets in her garage. On 11/14/18 became aware that?was being abused. quit working at Miracle Bush and contacted me. She informed me that she was in possession of the bucket seats obtained a search warrant to seize the tabte and bucket seats. These items match the description that .. . gave of the bucket seats that the children were restrained in On 11/28/18 I obtained records from inspections that were done by Department of Human Services. One inspection on stated ?observed two school? ?age children cteaning the ?oor on their hands and knees with rags containing bleach water.? Based on the information set forth within this complaint, I respectfully request Linda NOLAN be asked to answer to these charges. (Signature of Affiant) 4110 - Rev. 07MB .. Page_of