Filed: 5/9/2024 8:45 AM

Clerk
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ISP CASE NUMBER ZBISPC010364

SEARCH WARRANT 54

Probable Cause Affidavit

LIST OF PROPERTY, OBJECTS, THINGS,
INFORMATION OR PERSONS SEIZED OR PRODUCED
AFFIDAVIT
STATE OF INDIANA ) IN THE CLARK CIRCUIT COURT
) SS:
COUNTY OF CLARK I

IN THE MATTER OF ) CAUSE NUMBER:

A REQUEST FOR THE ) 10C01-23 07-MC-001423
ISSUANCE OF A )
SEARCH WARRANT )

Lieutenant Jeffrey C. Hearon, of the Indiana State Police Department, swears or affirms that he
believes and has probable cause to believe that certain documents, hereinafter described is
concealed in, or upon, the following described property, to wit:

Westside Auto & Repairable

123 West Main Street
Austin, Indiana 47102

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$11.!—
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The property or data to be seized or documented, which constitutes unlawfully obtained

property, contraband, property used or possessed with the intent to use in the commission or
concealment of an offense of corrupt business practices, ghost employment, official misconduct,
theft, and tax evasion, is described as follows:

A black 1970 Chevrolet Corvette Stingray VIN 1946708406761

2
STATEMENT OF PROBABLE CAUSE

Affiant's Experience:

I, Indiana State Police Lieutenant Jeffrey C. Hearon, being a duly sworn peace officer for the
State of Indiana, have been employed by the Indiana State Police for 35 years.

Your affiant, Jeffrey C. Hearon, a law enforcement officer with the Indiana State Police, being
duly sworn, swears and affirms under penalties for perjury that the following statements are true
and accurate to the best of my knowledge:

I am a police officer with the Indiana State Police. I have been a police officer with the Indiana
State Police since 11/13/1988. I am a "law enforcement officer" as that term is defined in Ind.
Code 35-31.5—2-185.

I am currently assigned as a Lieutenant to the Area V Field Investigations of the Indiana State
Police. In connection with my official duties, I am involved in investigations relating to violations
of the Indiana Criminal Code.

I have received training relating to the enforcement of the Indiana Criminal Code, including the
following:
A. My initial training at the Indiana Law Enforcement Academy in 1988. I
have satisfied the minimum basic training requirements established by rules adopted by the
law enforcement training board under I.C. 5-2-1-9 and described in I.C. 35-37-4
B. I have attended numerous additional training courses; see attached
transcripts.

As a result of my training and experience, I am familiar with the techniques and methods of
operation used by individuals involved in criminal activity to conceal their activities from
detection.
Investigation:

In support of affiant's assertion of Probable Cause, the following facts are known to affiant, to
wit:

On June 13, 2023, I was assigned a criminal investigation after current Clark County Sheriff
Scott Maples reported several criminal allegations of Official Misconduct against former Clark
County Sheriff Jamey Noel. Jamey Noel was the Clark County Sheriff from January 1, 2015,
through December 31, 2022.

Mark Grube for specific allegations and witness information.

I was directed to contact Colonel
On June 22, 2023, contacted Colonel Grube, and he advised there were several allegations,
I
some of which were as follows:

o
Jamey Noel assigned four of the Clark County Jail Maintenance employees to work on
his rental property, private business buildings (New Chapel EMS and Utica Township
Volunteer Fire Fighters Association), pole barn, cars, and private residence while being
on duty and being paid as Clark County employees.
o
Jamey Noel sold county vehicles and equipment, at a discount price, to employees who
worked on his personal vehicles, property, and non-profit businesses.
o
Jamey Noel, as sheriff, received millions of dollars in military surplus equipment and
acquired some of this property for his personal use.

of investigators from the Indiana State Police, Indiana State

I formed a joint taskforce consisting
Board of Accounts, Indiana Attorney General, Department of Defense Investigators, and Indiana
Department of Revenue. Approximately forty-two subpoenas and fifty-three search warrants
were issued.

On August 16, 2023, I formed four teams of detectives, uniform troopers, an Indiana Department
of Revenue Agent, and State Board of Account Investigators and served four search warrants at
the following locations: Jamey Noel's residence, Jamey Noel's Pole Barn, Utica Township
Volunteer Fire Fighters Association Station 1 and 2.

At the locations, I found numerous tax statements, bank documents, credit card receipts, not-for
profit board minutes, and financial records for the Utica Township Volunteer Fire Fighters
Association, New Chapel EMS and Fire, Utica Township Fire Department, New Chapel Fire
Incorporated, and other assumed business names associated with the above entities, as well as
Jamey Noel and his family, including but not limited to Misty A. Noel and Kasey Noel.
Additionally, the documents revealed Jamey Noel was the Chief Executive Officer, Chief
Financial Officer, and Fire Chief for the above-named businesses.

I obtained copies of the Utica Township Volunteer Fire Fighters Association (UTVFFA) 1954
Articles of Incorporation, UTVFFA Amended Articles of Incorporation 1993, UTVF FA
Application for Reinstatement 1993, and the UTVFFA Indiana Secretary of State Business
Entity Report 2022 listing Jamey Noel as the Chief Executive Officer. The various Articles of
Incorporation and reports submitted to the Secretary of State indicate that Jamey Noel has been

4
connected with the fire departments since the 1990's and has held various Board and Officer
positions, including Chief Executive Officer and Secretary, and was responsible for a number of
the business filings and reports required by the Secretary of State's Office.

During this investigation I contacted the listed board of directors and determined prior to August
2023 there had not been a board meeting in several years, and the members indicated Jamey
Noel had acted independently absent board participation.

With the assistance of Indiana State Board of Accounts, the total annual income for all the above
businesses and New Chapel Fire, Inc., which is an assumed business name for Utica Fire
Department (below), is estimated at approximately seven to eight million dollars of which
approximately two million is tax dollars or public funds.

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Indiana Code 36-8-11 allows for a county legislative body to establish fire protection districts in
each of the 92 Indiana counties. For the purposes of this investigation, Jamey Noel and his
affiliated companies received public funding from the Utica Township Fire District in Clark
County and the New Albany Township Fire Protection District in Floyd County.

The Clark County Commissioners created the Utica Township Fire District and appointed three
board members to run the district. The Board has the authority to levy taxes to fund fire
protection in the district.

According to CFO Erik Furnish, New Albany Township Fire District, New Chapel Fire
Incorporated, via Jamey Noel, contracted with the New Albany Township Fire Protection
District sometime around 2010-2012. Mr. Noel proposed that the fire district would own the
building and equipment and New Chapel Fire, Inc. would provide paid staff and run daily
operations, with Jamey Noel being the New Albany Township Fire Chief. CFO Furnish advised
the amount of the annual contracts have changed throughout each year but confirmed the 2022
contract was approximately 1.2 million dollars.

5
During the execution of the search warrants on August 16, 2023, I found several American
Express receipts indicating Jamey Noel had at least one credit card account. On September 14,
2023, a subpoena was sent to American Express for all accounts associated with Jamey Noel. On
January l8, 2024, American Express sent the following summary:

(l) American Express has identified concerning activity on Business Gold charge card
account number — associated with Utica Township FF AS, Gold charge
—
card account number and Bonvoy Brilliant credit card account
number— all issued to Jamey Noel.

(2) Specifically, between October 4, 2018, and Novemberl6, 2023, charges totaling
$730,992.93 were made to the Business Gold card account. Charges predominantly
appear personal in nature, such as charges at department stores, cigar stands, and jewelry
stores, which is not the intended use of the card product type and may be indicative of
mrsuse.

(3) Between October 20, 2018, and November 24, 2023, 83 payments totaling $4,113,106.43
were made to the Subject accounts. Internal records indicate the Business Gold card
account was opened in January 2011, the Gold card account was opened in March 2021,
and the Bonvoy Brilliant card account was opened in February 2012.

(4) Between October 4, 2018, and November l6, 2023, 1,295 charges totaling $730,992.93
were made to the Business Gold card account. Charges were conducted predominantly in
the United States, and appear to fund personal and household expenses, which is an
unusual pattern of spending for an OPEN business card associated with a non-profit and
raises concerns about misuse. Spending was primarily conducted at tailors and
seamstresses, home supply warehouse stores, department stores, cigar stores, for jewelry
and for ticketed events and travel agents. Charges do not appear related to services
provided by the Utica Township Fire Fighters Association or normal business expenses.
Between October 20, 2018, and November 24, 2023, 83 payments totaling $4,113,106.43
were made to the Subject accounts.

On January 21, 2024, American Express officials advised there were a total of five American
Express card holders for cards linked to the Utica Township Volunteer Fire Fighters Association.
They advised an additional court order would be needed to identify the other card holders. On
January 22, 2024, I requested and received a search warrant to identify all card holders and
purchases made by those persons. On January 25, 2024, American Express provided 1,729 pages
of charges, payments, and statements associated with the Jamey Noel, Misty Noel, Kasey Noel,
Matthew Owen (UTVFFA Board Member), and Kevin Wilkerson (UTVFFA Board Member).

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Below is a breakdown of Jamey, Misty and Kasey Noel's American Express purchases per
month and year.
AMERICAN EXPRESS CHARGES 0N UTICA BUSINESS GOLD REWARDS ACCOUNTS

Misg Noel 2020 2021 2022 TOTAL

January 5 8,061.96 $ 12,879.72 5 5,025.60 $ 11,833.45
February 3 4,495.88 9 9,036.70 3 12,520.56 $ 5,568.89 $ 10,503.49
March $ 8,060.78 $ 10,348.33 $ 15,997.43 $ 11,590.70 5 14,013.96
April $ 10,366.91 $ 8,991.93 S 8,531.35 $ 13,380.83 3 14,725.39
May $ 11,821.20 5 13,857.35 3 9,798.80 $ 10,553.14 $ 16,351.76
lune 5 8,588.90 $ 12,288.01 $ 8,659.47 $ 11,550.78 $ 11,773.27
July $ 11,478.17 5 12,120.69 5 12,808.90 $ 15,036.32 $ 10,041.34
August $ 13,434.47 3 12,657.24 3 6,373.93 $ 10,073.75 $ 6,579.34
September $ 11,932.72 $ 11,711.19 9 8,325.58 $ 11,753.48
October $ 19,135.84 $ 13,246.31 $ 11,782.90 $ 14,993.29
November $ 15,317.23 $ 14,904.67 $ 10,710.35 $ 16,753.51
December $ 17,636.88 $ 21,983.76 $ 20,531.65 $ 18,306.59
5 132,268.98 $ 149,208.14 3 138,920.64 5 144,586.88 5 95,322.00 I [S 660,806.64

The above charges were all personal items or services, and no personal payments were received from
Jamey or Misty Noel. All the payments for the items were charged to the Utica Township Volunteer Fire
Fighters Association.

American Express provided a detailed payment and purchase history. An analysis of the records indicated
Misty Noel made purchases for clothing, tanning, cosmetics, manicure and pedicure services,
jewelry, food, tickets, trips, college books and tuition associated items, dental services, alcohol,
phone bills, household utilities, Amazon items, and various household goods.

Ja mey Noel 2018 2019

1 2020 2021 £12; fig TOTAL
January S 38,369.08 $46,198.41 $ 25,452.10 $ 34,983.73 $ 70,679.61
February $ 46,563.25 $23,023.72 $ 62,472.68 $ 44,480.97 $ 55,935.65
March 5 74,480.67 $33,545.59 $ 104,294.75 5 36,576.79 $ 58,388.61
April $ 49,329.90 $40,727.21 $40,520.46 $ 45,825.90 $106,668.35
May $ 57,131.26 $49,259.86 5 64,061.43 $ 63,705.61 $ 54,183.10
June $ 28,957.87 $29,211.80 $ 87,366.06 $ 43,144.19 $ 60,050.53
July $ 26,417.18 $46,323.88 $26,439.08 $ 49,189.89 5 35,570.61
August 5 24,743.12 $83,584.86 $ 44,034.90 $ 56,745.49 S 36,836.85
September 5 36,376.11 $49,909.76 5 59,906.51 $ 79,927.37 5 15,405.80
October $ 20,695.39 $ 22,570.93 $ 41,336.13 5 39,725.01 5 62,246.75
November 3 24,992.93 $ 20,028.22 $ 20,996.26 5 33,071.74 $ 44,016.84
December $ 25,889.79 5 72,315.03 $47,290.90 $ 38,948.02 $ 96,558.27

I
s 71,573.11 $497,232.62 $511,408.38 $ 626,292.74 $657,401.80 I $493,719.11l 5 2,857,682.76

The above charges contained personal items or services, and no personal payments were received from
Jamey or Misty Noel. All the payments for the items were charged to the Utica Township Volunteer Fire
Fighters Association.

American Express provided a detailed payment and purchase history. An analysis of the records indicated
Jamey Noel made purchases for clothing, cigars, jewelry, food, tickets, trips, college books and
tuition associated items, medical services, alcohol, phone bills, household utilities, Amazon
items, Victoria's Secret, auto parts, personal taxes, vacation properties, and various household
goods.

7
Below is a breakdown of Kasey Noel's American Express purchases per month and year.

Kasey Noel 2019 L20 2021 2022 2023 TOTAL

January $2,071.24 $3,841.43 $4,899.15 $1,343.71
February $2,228.65 $1,213.29 $1,924.00 $1,532.25
March $3,001.65 $2,511.64 $873.37 $1,784.78
April $3,211.93 $1,742.21 $1,253.50 $1,765.80
May' $3,283.73 $2,263.90 $1,851.07 $1,178.10
June $2,001.20 $1,877.79 $1,838.76 $1,370.00
July $2,082.62 $2,000.23 $2,932.35 $3,476.58 $1,986.80
August $3,023.84 $2,694.15 $1,737.52 $873.23 $1,002.69
September $2,921.29 $2,649.81 $1,841.00 $907.00 $175.91
October $4,184.31 $1,807.58 $3,179.56 $1,993.26
November $3,960.27 $886.59 $2,040.85 $1,201.09
December $2,576.54 $1,871.23 $1,751.24 $2,039.90

$18,748.87 $27,707.99 ] $26,932.78 $23,130.91 $12,140.04 I $108,660.59

AMERICAN EXPRESS
BUSINESS

The above charges appear to be personal items or services, and no personal payments were received from
Kasey Noel. All the payments for the items were charged to the Utica Township Volunteer Fire Fighters
Association.

American Express provided a detailed payment and purchase history. An analysis of the records indicated
Kasey Noel made purchases for clothing, tanning, cosmetics, manicure and pedicure services, food,
alcohol, medical services, vaping products, gas, pharmacy, Netflix, Amazon items, and various
household items.

The above information indicates Jamey, Misty, and Kasey Noel received income, merchandise,
and services they failed to report to the State of Indiana, Department of Revenue more than 3.5
million dollars during the years 2018, 2019, 2020, 2021 and 2022.

Additional analysis was completed on the American Express purchases and the buying patterns
were reviewed for Jamey, Misty, and Kasey Noel. The larger purchases were categorized as
follows:
 Jame! Noel Kasey Noel Misg Noel

1 Alcohol & Tobacco $75,334.07 $1,138.40 $621.52

2 Apartment Rental $21,236.36 $791.83

3 Beauty $27,651.57 $11,687.36 $125,693.35

4 Child Support $54,003.51

5 Clothing $213,116.75 $29,683.87 $165,151.44

6 Donations $27,722.76 $5,887.97

7 Education/Tuition $162,068.37 $32,421.98

8 Entertainment $64,433.78 $3,453.05

9 Food $228,536.82 $11,814.38 $46,551.61

10 Furniture & De'cor $36,283.52 $9,480.54

11 Guns $4,516.40
12 Home Appliances $16,960.63
13 Jewelry $57,406.30 $2,083.58
14 Retail Stores $158,329.91 $7,028.88 $132,618.32
15 Time Share & Travel $327,862.55 $638.50 $13,282.45
l6 Utilities $99,073.63 $1,093.49 $15,609.51
l7 Health Care $16,054.15 $8,402.65 $16,370.66
18 PayPal $38,291.22 $810.37 $15,368.52
l9 Venmo $27,437.14 $15,397.41

Additional search warrants were obtained for PayPal, Venmo, Synchrony Bank, and a second search
warrant was obtained for American Express because of a continued pattern of purchase/charging activity
on the account after the November 9, 2023, arrest of Jamey Noel. The above business provided monthly
statements and additional information which is being reviewed.

The Utica Township Volunteer Fire Fighters Association Board of Directors and Staff Attorney Heather
Archibald-Peters reached out to ISP pursuant to an ongoing internal review and provided bank records,
wire transfer information, and copies of bank cashier checks, which they believed indicated a pattern of
theft and embezzlement. Additionally, the UTVFFA Board voted to authorize the Indiana State Police to
seize any and all stolen assets belonging to the UTVF FA in the possession of Jamey Noel or his family.

A periodic inquiry of Jamey Noel's BMV title history was conducted and on April 16, 2024, it appears
someone requested duplicate titles for several vehicles owned by Jamey Noel. The request for duplicate
titles possibly indicates an intent to sell some of Jamey Noel's car collection. As a result of the duplicate
title request, I reviewed several vehicle purchase histories of vehicles registered to Jamey Noel.

9
 title_mmber CUSTGl/l ER_U ID CU SI'OM ER_NAME TRANS_TYPE_CODE TRANSACTION_UJD IDEN'I'IFlCAnON-NUM BER
232 74 2300108 13 4012657 JAMEY JOHN NOEL Duplicate Title 372719619 85319566
232 74230010814 4012657 JAMEY JOHN NOEL Duplicate Title 3 72719620 T571816

23274230010815 40176" mmrv mum mru n...-.I* o Tflh' 1791mm! yams

4012657 JAMEY JOHN NOEL Duplicale Tnle 372719622 194670996 761
<23§22724230010316 Dupliramlnb 177710A7~ 1
232 74 23 00 108 18 4012657 JAMEY DHN NOEL Duplicate Title 372719624 2351768611834
23274230010859 4012657 JAMEY JOHN NOEL Duplicate Title 372719668 RM23H96195995
232 74230010888 4012657 JAMEY JOHN NOEL Duplicate Title 372719707 WM23mE107650
232 74230010889 4012657 JAM EY JOHN NOEL Duplicate Title 372719710 6808046775
23274231005345 4012657 JAM EY JOHN NOEL Duplicate Title 372749069 124678N325084
23274264003873 4012657 JAMEY JOHN NOEL Duplicate Title 374097763 2Y86H424651
23274292003665 4012657 JAMEY JOHN NOEL Duplicate Title 375254549 CP46T60191308
233 712360001 10 3995959 MISTY ALENA NOEL initiaITitle Issuance 377034384 WDDNGBGXX7A102517
243 71053000211 41505319 KASEY ALEXANDRA NCEL Title Transfer 381235546 36KALMEV1JL270404
24371067000203 42851230 GRACY ABIGAYLE NCEL lnitlalTitle Issuance 382170340 WBAFR7G9DC827187
243 71067000205 42851230 GRACY ABIGAVLE NOEL InltialTitle Issuance 382171580 WDDUG8FB7FA113330
24274107009527 4012657 JAMEY JOHN NOEL Duplicate Title 382669455 T571816
242 74 10 70095 28 4012657 JAMEY JOHN NOEL Duplicate Title 382669456 2FAHP71V68X156399
242 74 10 7009529 4012657 JAMEY JOHN NOEL Duplicate Title 382669457 85319566
242 74 10 70095 30 4012657 JAMEY JOHN NOEL Duplicate Title 382669458 RM23H96195995
242 74 10 70095 31 4012657 JAMEY JOHN NOEL Duplicate Title 382669459 VG7BZ64776

A review of the title history for a

1970 Chevrolet Corvette registered to Jamey Noel was conducted, and it
was determined that Mr. Noel purchased a Corvette from Mccum Auction on September 3, 2018, for
$23,410.10 which included taxes and buyers' fees.

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A review of the Mecum's Auction purchase paperwork was performed, and it was determined
that Jamey Noel charged $10,063.64 to the Utica Township Volunteer Fire Fighters Association
American Express Card and provided no reimbursement for the down payment on two vehicles
(1970 Corvette and a 1971 Camero).

10
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American Express Card Statement:

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09/1 ms www.rrUNES.c0M/81LL cupmmo CA $17.03
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09/1 1/18 HOSPARUS. INC 1 LOUISVILLE KY $100.00
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09/12/18 AT&T DATA W260 ALPHARElTA GA $50.00
8003310500
09/12/18 LOWE'S cumsvmi m 51,115.53
812-2583100

On April 30, 2024, I received information the 1970 Corvette was being repaired at Westside
Auto & Repairable, 123 West Main Street, Austin, Indiana, 47102. I contacted the owner, John 1.
White, and he confirmed the vehicle was on his property waiting to be repaired. I requested I be
informed if the vehicle was removed from the property.

11
Based on the above information and past patterns of fraud, layering, and embezzlement, I am
requesting a search warrant to search for and seize the 1970 Chevrolet Corvette listed above.

Conclusion:

I am currently investigating a ghost employment, tax evasion, theft, corrupt business practices
and official misconduct case involving former Clark County Sheriff, former Utica Volunteer Fire
Fighters Association Chief Jamey Noel, and his wife Misty Noel, daughter, Kasey Noel and his
various associates. I anticipate providing the special prosecutor With additional information for
potential additional charges as the State Board of Accounts and the Indiana Department of
Revenue complete their audits and investigations.

The facts set forth in this affidavit are based upon my own personal observations, my training
and experience, and information obtained during this investigation, along with my mapping and
analysis of the data. Therefore, based on the above facts, I have probable cause to believe, and do
believe, that evidence of the commissions of felonies, in violation(s) of Indiana Code 35-44.1-l-
3 Ghost Employment, 35—43-4-2 Theft, 35-44.1-2-2 Obstruction of Justice, 35-45-6-2 Corrupt
Business Influence, 35 —44.l-l-1 Official Misconduct, and 6—3-6—11 Tax Evasion property related
to the commission of said felonies.

I declare under penalty of perjury that the foregoing is true and correct to the best of my
knowledge and belief.

All of the above events occurred in Clark County, Indiana.

I swear (affirm), under penalty of perjury as specified by IC 35-44—2-1, that the foregoing
representations are true.

DATED: May 7, 2024 /s/ Lieutenant Jeffrey C. Hearon PE 5201 AFFIANT

l2