Filed: 7/3/2024 9:22 AM

e STATS Clerk
Clark '2'
County, Indiana
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13p CASE NUMBER 23ISPC010364

SEARCH WARRANT 57
-

Probable Cause Affidavit

LIST OF PROPERTY, OBJECTS, THINGS,A
INFORMATION OR PERSONS SEIZED OR PRODUCED
AFFIDAVIT
'

STATE OF INDIANA IN THE CLARK CIRcUIT COURT

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) SS:
COUNTY OF CLARI< )

IN THE MATTER 'OF' ,

), CAUSE NUMBER:
A REQUEST FOR THE ) _.

ISSUANCE OF A 10C01-2407-MC-001423
'

)
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 digital records, or upon, the following described property, to wit:

Allegiant Travel Company

1201 North Town Center Drive,
. Las' Vegas Neveda 89144
Attention: Alexia Carnetti

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:

"Any and all billing and account information including but not limited to the following:
subscriber information, purchase history, card holders, monthly statements, payment
history, including canceled checks, bank-account numbers, wire transfers, Automated

1
Clearing House (ACH) Payments, Electronic Funds Transfer (EFT), credit card numbers,
correspondences, mailing addresses, and email addresses for the following
people/businesses:

1. Jamey John Noel

_
Date of birth;
Gender; Male
SSN —

2. Misty Alena Noel

DOB —
SSN-
3. Kasey Alexandra Noel

DOB _
SSN—
4. Utica Township Volunteer Fire Fighters Association dba New Chapel Fire and EMS

STATEMENT 0F "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.

2
I have received training relating to the enforcement of the Indiana Criminal Code, including the
following:
My initial training at the Indiana Law Enforcement Academy in 1988.
A. I
have satiéfied the minimum basic training requirements established by rules adopted by the
law enforcement training board under LC. 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
conceal their activities from
operation used by individuals involved in criminal activity to
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.

I was directed to contact Colonel Mark Grube for specific allegations and witness information.
On June 22, 2023, I contacted Colonel Grube, and he advised there were several allegations,
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.

I'formed a joint taskforce consisting of investigators from the Indiana State Police, Indiana State
Board of Accounts, Indiana Attorney General, Department of Defense Investigators, and Indiana
warrants were
Department of Revenue. Approximately forty-two subpoenas and fifty-six search
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.

3
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, UTVFFA
Application for Reinstatement 1993, and the UTVFF A 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
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.

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During this investigation I contacted the past and present 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, but he Was never
authorized to purchase personal items, trips, timeshares, jewelry, personal vehicles, pay his
personal property taxes, and utilities with not—for—profit funds.

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. Total public
funds received by New Chapel EMS, for the SBOA examination period 2019 to 2023, were
$3,886,388.80.

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 During the period of this examination. New Chapel EMS received a total of $3,886,388.80 of public
funds from Clark and Floyd counties.

Clark Floyd
Year County County Totals

2019 S -
S 177,222.23 S 177,222.23,
2020 116,666.66 238,333.29 354,999.95
2021 699,999.96 219,999.96 919,999.92
2022 962,499.99 201,666.63 1,164,166.62
2023 1,050,000.00 220,000.08 1,270,000.08

Totals 5 2,829,166.61 S 1,057,222.19 55 3,886,368.80

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 25, 2024, American Express provided 1,729 pages of charges, payments, and
statements associated with the Jamey Noel, Misty Noel, Kasey Noel, and other card holders. A
review of the charges made by Jamey, Misty, and Kasey Noel were for personal purchases and
suspected to be evidence of theft and tax evasion.

Below is a breakdown of Jamey, Misty and Kasey Noel's American Express purchases per year.

Jamey Noel:
Distributions Made by Noel from the New Chapel EMS American Express Credit Cards
' '

Category 2019 2020 2021 2022 2023 Totals

Alcohol 8. Tobacco " S 11,407.46 S 12,298.19 S 24,915.35 5 16,588.46 S 6,711.56 S 71 321.02

Auctions 582.75 -
7,398.85 51.62 2,198.23 1 0,231.45

Alrcrait and Automotive 30,284.64 20,114.72 16,030.72 36,713.69 45,892.47 149,036.24

Beauty Products and Clothing 18,240.96 10,787.41 8,048.74 12,521.85 3,237.08 52,836.04
Digital Media and Soflware 4,372.28 6,241.16 3,264.96 2,958.14 3,968.51 20,805.05
Donations e 887.00 7,650.04 1,477.00 20,646.52 2,577.50 33,238.06
Education/Tuition 6,032.47 123.01 226.00 1,249.00 1 .7308? 9,361.35
Entertainment Movies, Sports,
-

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Events, Concerts 12,600.00 10,076.14 6,011.21 18,822.72 11,288.25 58,798.32
Equipment Computers, Phones,
-

Phone Accessories 5,476.83 7,275.96 1, 593.23 3,062. 15 3,106.90 20,51 5.07

Food -

33.089.90 48,040.18 47,764.40 64,427.46 34,045.98 227,367.92

Gas Station/Convenience Stores 4,415.97 3,707.81 5,174.40 4,065.55 5,252.46 22,616.19
Health 8- Health Care Professionals 9,737.32 207.34 2,716.74 1,544.75 1,717.48 15,923.63
Furniture and Home lmprmement 49,947.44 30,362.18 71,071.99 28,613.69 22,670.24 202,665.54
insurance 2,139.87 2,581.00 9,914.45 3,905.87 22,685.53 41,226.72
Interest 13,199.41 11,248.15 13,176.24 18,253.98 13,378.52 69,256.30
7
Jewelry 11,063.30 -
1,072.00 44,835.00 -
56,970.30
Membership and Service Fees 543.52 551.14 1,006.38 726.54 493.00 3,320.58
Mobile Payment 3 31,803.77 21,514.15 45,299.92 53,072.47 11,486.21 163,176.52
'
Retail Stores and Online Retail Outlets 48,200.67 117,684.68 82,078.72 61,015.98 57,499.90 366,479.95
Taxes 20,081.37 8,165.82 17,415.08 16,651.76 31,725.92 94,039.95
Travel/"lime Share 48,330.47 82,1 82.34 82,749.55 -. 72,167.22 37,741.47 323. 1 71.05
Other 21,528.04 5,318.86 14,243.03 12, 1 74.46 4,279.21 57,543.60
Utilities 17.451 .97 18,952.33 18,768.06 21,804.92 17,507.68 94,484.96

Totals $401,417.41 $425,082.61 $481,417.02 $515,873.80 $341,194.97 $2,164,985.81

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The above charges contained personal items or services, and no personal payments were received
from Jamey or Misty Noel. A11 the payments for the items were charged to the Utica Township
Volunteer Fire Fighters Association.

Misty Noel:
Distributions Received by Misty Noel from the New Chapel EMS Amen'can Express Credit Card
Category 2019 2020 2021 2022 2023 Totals

Beauty'
'
S 15,422.91 s 27,750.67 $ 29,696.76 $ 32,371.07 $18,499.78 $123,741-19
Clothing and Jewelry 47,408-19 30,588.14 29,88290 35,462.19 17,180.61 160,522.03
Education/Tuition 10,227.62 8,263.53 13,196.82 845.80 1,319.37 33,853.14
Entertainment _
1,737.38 - —
356.65 1,389.16 3,483.19
Food 7,855.89 12,178.96 7,762.12 10,052.06 10,104.90 47,953.93
Gas Station/Conwnience Stores 1,220.00 337.40 195.41 97.99 48.22 1,899.02
Healthcare 971.47 3,291.40 2,100.59 2,601.80 6,215.32 15,180.58
Home Improvement 1,379.78 2,950.61 797.06 5,274.00 2,529.62 12,931.07
Mobile Payment 1,475.54 8,241.43 4,053.78 601.61 1,249.22 15,621.58
Online Retail 11,284.56 16,6967 11,16232 12,397.93 10,619.26 62,121.74
Other 3,856.95 2,688.85 4,159.25 6,464.82 4,795.23 21,965.10
Pet 380.92 2,376.83 2,776.52 4,354.95 1,403.88 11,293.10
Retail Stores 29,694.61 29,075.07 26,200.13 25,393.14 13,689.67 124,052.62
Trarel/Trme Share 2,180.25 '
1,29624 2514.74 4,928.72 2827.11 13,747.06
Utilities 2,694.05 2,781.13 3,179.71 3,860.60 2,331.08 14,846.?

Totals $137,790.12 $148,477.93 $137,678.11 $145,063.33 39420243 $663,211.92

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.
 Kasey Noel:
*-

Distributions Receixed by Kasey Noel from the New Chapel EMS American Express Credit Card
-' Totals
2019 2020 2021 2022 2023 ~

Category
.

38209 $ 157.99 3 161.61 5 308.59 $ 157.10 $ 1,167.38

Alcohol & Tobacco $
28.00 316.78 50.00 - -
394.78
Automotive
Beauty _
2,575.67 3,285.74 2,609.02 2,616.08, 1,702.25 12,788.76
Clothing and Jewelry 5,780.11 9,01293 7,671.35 4,861.35 4,603.79 31,929.53
986.81 1,343.33 3,529.22 1,713-04 851.46 8,423.86
Digital Media and Mobile Payments '

832.61 455.83 1,234.81 177.03 3,975.64

Equipment, Electronics, and Accessories 1,275.36
Fitness & Lifestyle 84-52 333.77 489.53 11235 39.58 1 ,059.75

Food 3,852.62 2,327.22 3,526.67 898.10 12,225.79

1,621.18
'Gas Station/Convenience Stores 921.29' '1,37227 1,104.21
'
695.64 136.89 4,230;30
Health & Health Care Professionals 413.00 26203 4,042.86 3,629.07 95.00 8,441.96
Home lm provement 1,139.20 436.52 71.67 -
39.99 1,687.38
Online Retail 637.01 1,179.28 51242 325.79 671.93 3,326.43
'

Pet 67-93 372.04 464.42- 344.26 263.61 1,512.26

'

Retail Stores 1,620-72 3,088.22 1,321.58 65265 502.57 7,185.74

77.00 495.00 56200 -
708.00 384.00 2,226.00
Shipping/Postage
518.80
'

Software/Online Sem'ces 327.99 435.96 250.98 817.54 2,351.27

'

Travel/Time Share 41.02 -

116.00 828.00 344.71 1,329.73
Other 144.81 908.39 389.59 113.76 465.32 2,021.87
Utilities . - -
896.48 197.01 —
1,093.49

Totals $ 18,123.71 $ 27,685.48 5 27,025.99 5 22,684.61 $ 11,852.13 .

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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. ..

On November 9, 2023, Jamey Noel was arrested and chargedwith fifteen felonies. On February
1, 2024, Jamey Noel was charged with an additional ten felonies. The SBOA
issued two audit
and one for theft from Utica
reports, one for theft from the Clark County Sheriff's Department
Township Volunteer Fire Fighters Association. After Jamey Noel's arrest on November 9, 2023, '

additional'charges were made using the Utica Township Volunteer .Fire Fighters Association
American Express Card and the Utica Township Volunteer Fire Fighters Association Sam's Club '

Card. The purchases totaled more than $52,000.00 and are summarized below.

7
American Express Charges after Arrest November 9, 2023
'

A review of Jamey Noel's Utica Township Volunteer Fire Fighters ASsociation American
Express charges after November 9, 2023, was conducted and it was determined he charged an
additional $37,151.40 from Nevember 9, 2023, to March 29, 2024. The charges included
Cincinnati Reds, Uber, The Ridge Liquors, Spectrum, Sirius XM Radio, Nuyale Dry Cleaners,
Whistle Express, Kansai Japanese Steak House, Indy Star, Hagerty Insurance, Go Daddy, Clark
County REMC, Door Dash, AT&T Mobile, and Amazon. Jamey Noel was suspended from the
Utica Township Volunteer Fire Fighters Association on November 9, 2023, and terminated on
January 12, 2024.

Sam's Club Mastercard belonging to Utica Township Volunteer Fire Fighter Association
after November 9, 2023, arrest.

A review of Jamey Noel's Utica Township Volunteer Fire Fighters Association Sam's Club
Mastercard charges after November 9, 2023, was conducted and it was determined Jamey Noel
charged $15,667.56 from November 9, 2023, to March 17, 2024. The statements indicated
charges from Clark County 4H, Sacred Heart Church, Cleanwaves Express, Eagle Creek Golf
Course Naples Florida, Hooters, Mais Thai Restaurant, Krispy Kreme, Waffle House, Asian
Buffet, El Nopal Mexican, Whistle Express, Star Sushi, Schimpst Confectionery, Skyline, and
Meij er. Jamey Noel was suspended from the Utica Township Volunteer Fire Fighters
Association on November 9, 2023, and terminated on January 12, 2024.

As part of the investigation the various restaurants, businesses, and service providers were
contacted and receipts, invoices, and billing documents were requested. Some of the various
organizations require a court order to provide the requested documents.

Allegiant Travel Company

On April 22, 2024, I reviewed the UTVFFA American Express charges for Allegiant Travel
Company and determined that Jamey, Misty, and Kasey Noel charged the following amount
from Allegiant Travel using the Utica Township Volunteer Fire Fighters Association Business
American Express Card:

Jamey Noel $55,953.69

Misty Noel $3,461.36
Kasey Noel $738.00

I contacted Alexia Canetti, Allegiant Travel Company Paralegal, and requested records
associated with the approximate $60,153.05 in Utica Township Volunteer Fire Fighters
Association charges. Ms. Canetti advised Allegiant Travel Company requires a couit order to
provide records.
Based on the above information, I am requesting a search warrant for the records of purchases
made by Jamey Noel, Misty Noel and Kasey Noel from Allegiant Travel Company, which does
business in the state of Indiana.

Conclusion

I am 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.

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
do
analysis of the data. Therefore, based on the above facts, I have probable cause to believe, and
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.l-2-2 Obstruction of Justice, 35-45-6-2 Corrupt
Business Influence, 35-44.1-1-I 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: July 1, 2024 /s/ Lieutenant Jeffrey C. Hearon PE 520i AFFIANT