Filed: 3/19/2024 3:19 PM

40"
a STATS Clerk
ok
"It! "'14 Indiana
Clark County,
REDACTED <§
"z
'2?
i'* '9
}2
lb
a.\
.'s 'i—
'8l

ISP CASE NUMBER 231$PC010364

' '

SEARCH WARRANT 47'

Probable Cause Affidavit

'
LIST OF PROPERTY, OBJECTS, THINGS,
INFORMATION OR PERSONS SEIZED OR PRODUCED
AFFIDAVIT
STATE 0E INDIANA T 1N THE CLARK CIRCUIT COURT
) ss:
COUNTY 0F CLARK w

1N THE MATTER 0E ) CAUSE NUMBER:

A REQUEST FOR THE ) 10C01—2307-MC—001423
ISSUANCE OE 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:

PayPal Inc.— Venmo (a PayPal Inc. Service)

ATTN: Global Investigations
2211 North First Street
San Jose, CA 95131

VIA: https://safetyhub.paypalc0rp.com

The property to be seized or documented, which constitutes unlawfiilly 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:
 Venmo/PayPa'l records, data, or information for Venmo/PayPal user identified as Jamey
Noel, Misty Noel, Kasey Noel, Josey Noel, and Gracy Noel between the dates of August 1,
2018, through March 17, 2024, for evidence of the crimes of corrupt business practices,
ghost employment, official misconduct, theft, and tax evasion:

All subscriber information for the following people:

1. Jamey John Noel

—
Date of birth;
Gender; Male
SSN —
2. Misty Alena Noel

-
—
DOB
SSN

3. Kasey Alexander Noel

DOB
SSN

4 Josey Ann Noel

SSN—
5. Gracy Abigayle Noel

SSN
4

All billing and account information, including:

o Device identifiers/any identifiers transmitted by the end user's device, including but not
limited to, International Mobile Equipment Identity (IMEI), International Mobile
Subscriber Identity (IMSI), Integrated Circuit Identification (ICCID) also known as the
Subscriber Identity Mobile (SIM) card identification or serial number, Internet Protocol
(IP) addresses, Media Access Control (MAC) address, hardware identifiers such as the
manufacturer serial numbers, and operating system specific identifiers;
 All credit card, debit Card, payment card, and/or financial institution account number(s)
"

associated with or used by the accounts;

o
Any associated financial institutions and/or accounts;
o
Any associated phone numbers.

Location information, including Internet Protocol (1P) information, Global Positioning System
(GPS) data/locations, transaction location information, and IP address(es) used to conduct
transactions by account.

Any and all transaction information/data, including physical location information, transaction
location information, IP address(es) used to conduct transactions by account, and any/all
transaction history, including, but not limited to:
o Transaction amount(s);
0
Date(s);
o
Memo(s), note(s), or other metadata;
o Linked bank account numbers;
o Linked debit/credit card account numbers;
o
Identity information for any/all accounts, identities, entities, and/or usernames conducting
transactions with the target accounts, listed above;
o Location data.

Communication content, including internal or external, with the account holder and regarding
the account holder.'

Account status and information, including:

o E-mail address used to create the account;
o Alternate eemail addresses;
o Date identity/account registered;
o Internet Protocol (IP) Logs including but not limited to IP address(es) used to register the
acCount(s) and IP address(es) used to access the account(s).

Internet Protocol (IP) address information, including: all IP address information regarding the
IP address used at the time of account creation, and any IP address information'stored by PayPal
Inc Venmo for the above—listed target user(s)/account(s).
—

For which a search warrant and court order for production of records may be issued upon one or
more of the grounds set forth in 18 U.S.C. §2703, C.R.S. §16-3-30l, §16-3-30l.1 and Crim. P.r4l,
namely that this property has been stolen or embezzled, or which is designed or intended for use
as a means of committing a criminal offense, or which is or had been used as a means of
committing a criminal offense, or the possession of which is illegal, or which would be material

3
evidence in a subsequent criminal prosecution in this state, another state, or federal court, or the
seizure of which is expressly required, authorized, or permitted by a statute of this state or the
United States, or that would aid in the detection of the whereabouts of or in the apprehension of a
person for whom a lawfirl arrest order is outstanding.

Electronic Definitions

"Internet" means a global network of computers and other electronic devices that communicate
with each other. Due to the structure of the Internet, connections between devices on the Internet
often cross state and international borders, even when the devices communicating with each other
are physically located in the same state.

"Computers", "digital media storage", or "digital storage devices" may be used interchangeably,
and are intended to include any physical object upon which computer data can be recorded as well
as all types of electronic, magnetic, optical, electrochemical, or other high speed data processing
devices capable of performing logical, arithmetic, or storage functions, including desktop and
laptop computers, mobile phones, tablets, server computers, game consoles, network hardware,
hard disk drives, RAM, floppy disks, flash memory, CDs, DVDS, and other magnetic or optical
storage media.

Internet Service Providers "ISP's" or Electronic Service Providers "ESP's" are commercial
organizations that are in business to provide individuals and businesses access to the Internet. ISPs .

provide a range of functions for their customers including access to the Internet, web hosting,
email, remote" storage, and co-location of computers and ether communications:equipment. ISPs
can offer a range of options in providing access to the Internet including telephone-based dial—up,
broadband based access via digital subscriber line (DSL) or cable television, dedicated circuits, or
satellite-based subscription. ISPs typically charge a fee based upon the type of connection and
volume of data, called bandwidth, that the connection supports. Many ISPs assign each subscriber
an account name —
a username or screen name, an "email address," an email mailbox, and a

personal password seleCted by the subscriber. By using a computer equipped with a telephone or
cable modern, the subscriber can establish communication with an ISP over a telephone line or
through a cable system and can access the Internet by using his or her account name and personal
password.

"Internet Protocol Address" or "IP address": Every computer or device on the Internet is referenced
by a unique Internet Protocol address the same way every telephone has a unique telephone
number. An IP address is a series of numbers separated by periods; an example of an IP address is
192.168.10.102. Each time an individual accesses the Internet, the computer from which that
individual initiates access is assigned an IP address. A central authority provides each ISP a limited

4..
block of IP addresses for use by that ISP's customers or subscribers. Most ISPs employ dynamic
IP addressing, that is they allocate any unused IP address at the time of initiation of an Internet
session each time a customer or subscriber accesses the Internet. A dynamic IP address is reserved
by an ISP .to be shared among a group of computers over a period of time. The ISP logs the date,
time and duration of the Internet session for each IP address and can identify the user of that IP
address for such a session from these records. Typically, users who sporadically access the Internet
via a dial-up modem will be assigned an IP address from a pool of IP addresses for the duration of
each dial-up session. Once the session ends, the IP address is available for the next customer. On
the other hand, some ISPs, including most cable providers, employ static IP addressing, that is a
customer or subscriber's computer is assigned one IP address that is used to identify each and
every Internet session initiated through that'computer. In'other werds, a static IP address is an IP
address that does not change over a period of time and is typically assigned to a specific computer.
A modern is an electronic device that allows one computer to communicate with another.

Social Media: In general, social media may be defined as websites and applications that enable
users to create and share content or to participate in social networking.

IMEI: IMEI (International Mobile Equipment Identity) is a unique identification number that
identifies mobile devices.

IMSI: An international mobile subscriber identity (IMSI) is a unique number, usually fifteen digits,
associated with Global System for Mobile Communications (GSM) and Universal Mobile
Telecommunications System (U MTS) network mobile phone users. The IMSI is a unique number
identifying a GSM subscriber.

Cookie: A cookie is a small. amount of data generated by a website and saved by your web browser.
Its purpose is to remember information about you, similar to a preference file created by a software
application. One purpose of a cookie is to save log in and password information for an account. It
also serves the purpose of saving user preferences for a site, such as a search engine saving a search
or a news website saving a ceitain font you prefer.

S'TATEh/[ENT 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 affirnis under penalties for perjury that the following statements are true
and accurate to the best of my knowledge:

5
 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—3 7-4
B. I have attended numerous additional trainings; 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 l3, 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 CountySheriff 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 he
and Kenneth Hughbanks acquired some of this property for their 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

6
 Department of Revenue. Approximately forty-two subpoenas and forty 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 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, UTVF FA Amended Articles of Incorporation 1993, UTVFFA
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
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.

;s «'v' u
y, I , ,1"v at
a! "h; .x,. t'. "I" *1
lSl!
\
. .—
't L)" n: JV., .1 , I
-.
J' IX}! s
w

uni
,
v, —
A
. 42' h c \

Elfiness Seafcju ,. — . . .... ._ ._ ,

Ruflnes: gaunt] Mun

3012161 Nme Mmcnrz w. PM u: >1 ("up AAZm r\1»'s)("("l-V Sunx
. _..,

uxsoa11121414e GEIKO QRO'JP lLC liCHLlNAK Domesli: Umilw whirl-f Conpm/ 3:01 O'd lay BIUgr.kll;$clrI;¢'. ill;47!-JO USoS Jamey Heel Acu'w
~

nu \r: , . .
In . . ,
wm'n m: It'vw. ~,

53.20 UYIG' Ill )m'q Had MM.-

"5'""""L."'?'fi'fl'.5'}.'l'r'f'B-J'fi'li.
. _._ _'.. 91515959315353" '55'.°."£'°"'Ff'£'°""" . fitfi.
... )UEEI'LSIEIYILLE, US? 4713a). .,__ .—

IQM'OMZ'GL U] [A SECURITY (ROD? MWVH} 2W I};

.'.'.( Dammit Ilnnpox'x (up: .n' ka'fi UTICA "(L IUIIERSOHHILL BLAINE-VHS! Mm] um Mr

.33.'3'."1'.'f7.. marsh.79~5_="'~1s',=&v'5s5v1=75§fi_'"5"'"mm' ._. . _ _..

'59 'i'éf.' Wilt Hgnfmfu Cupurft m '3'?WNEJWLEL'YI'EFE'7yfy'A Auk:

9.9.1.".muuuus
1r
'8Return 3's "'33
.
.,_
.. _ ._ . _ .. . , ..._.

'5 m '. E D 5| ll'5 s 0'" "'3'

'
l
cumiasro .s. 1mm uremranm m. 41130.15 rw runknn Au!"
zoozouyxam uzw nu: .11 ms me mun:
52 1n
Cupomuou

7
 '

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 wouldown the
building and equipment and New Chapel Fire, INC would provide paid staff and iun 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.

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 18, 2024, American Express sent the following summary:

(1) American Express has identified concerning activity on Business Gold charge card
account number msociated 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 November16, 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, at cigar stands, and
jewelry, which 1s not the intended use of the card produCt type and may be indicative of
misuse.

(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 201 l, 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 16, 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, forjewelry
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).

Below is abreakdown of Jamey,.Misty and Kasey Noel's AmericanExpress purchases per

month and year.
AMERICAN EXPRESS CHARGES 0N UTICA BUSINESS GOLD REWARDS ACCOUNTS

Misg Noel £333 10;; TOTAL

January $ 8,061.96 $ 12,879.72 $ 5,025.60 $ 11,833.45
February 3 4,495.88 5 9,036.70 $ 12,520.56 5 5,568.89 $ 10,503.49
March 8 8,060.78 $ 10,348.33 $ 15,997.43 5 11,590.70 S 14,013.96
April $ 10,366.91 $ 8,991.93 $ 8,531.35 $ 13,380.83 $ 14,725.39
May $ 11,821.20 $ 13,857.35 $ 9,798.80 3 10,553.14 $ 16,351.76
June 5 8,588.90 $ 12,288.01 5 8,659.47 $ 11,550.78 $ 11,773.27
July $ 11,478.17 $ 12,120.69 $ 12,808.90 $ 15,036.32 $ 10,041.34
August $ 13,434.47 $ 12,657.24 3 6,373.93 $ 10,073.75 S 6,579.34
September $ 11,932.72 $ 11,711.19 $ 8,325.58 $ 11,753.48
October $ 19,135.84 $ 13,246.31 $ 11,782.90 $ 14,99329
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

[232.268.9815 149,208.14 $ 138,920.64 $ 144,536.88 5 95,322.00 I IS 650,806.64

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.

Jamey Noel 2018 2019 2020 2021 £12; 2023 TOTAL

January $ 38,369.08 $ 46,198.41 5 25,452.10 $ 34,983.73 5 70,679.61
February 5 46,563.25 $ 23,023.72 $ 62,472.68 $ 44,480.97 $ 55,935.65
Mareh _$ 74,480.67 $ 33,545.59 $104,294.75 $ 36,576.79 5 58,388.61
April 5 49,329.90 $40,727.21 540,520.46 $ 45,825.90 $106,668.35
May $ 57,131.26 $ 49,259.86 $ 64,061.43 $ 63,705.61 $ 54,183.10
June 5 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 5 49,189.89 $ 35,570.61
August $ 24,743.12 $ 83,584.86 9 44,034.90 $ 56,745.49 $ 36,836.85
September 5 36,376.11 $49,909.76 $ 59,906.51 5 79,927.37 $ 15,405.80
October 5 20,695.39 5 22,570.93 $ 41,336.13 $ 39,725.01 $ 62,246.75
November $ 24,992.93 5 20,028.22 5 20,996.26 5 33,071.74 $ 44,016.84
December 5 25,889.79 $ 72,315.03 $ 47,290.90 $ 38,948.02 $ 96,558.27

$ 71,578.11 $497,282.62 5 511,408.38 3 625,292.74l $657,401.80 I $493,719.11! 5 2,857,682.76

9
 The above charges contained personal items or services, and no personal payments were received fi'om
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 analyses 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.

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

Kasev Noel 2019 20 01

_2_02_; 0 TOTAL
January 32,07124 $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 8873 .37 $1,784.78
April $3,211.93 $1,742.21 $1,253.50 81,765.80
May $3,283.73 $2,263.90 $1,851.07 $1,178.10
June $2,001.20 $1,877.79 $1,838.76 51,370.00
July 82,082.62 $2,000.23 $2,932.35 $3,476.58 $1,986.80
August $3,023.84 $2,694.15 $1,737.52 $873 .23 81,002.69
September $292129 $2,649.81 $1,841.00 $907.00 S 1 75 .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

[58,748.87 327,70739 $26,932.78 $23,130.91 $12,140.04 $108,660.59

The above charges appear to be personal items or services, and no personal payments were received frorn
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 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:

10
 Jamcv Noel Kascv 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/1'uition $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 Fumilure & Décor $36,283.52 $9,480.54

ll Guns $4,5 16.40

12 Home Applianécs $16,960.63

13 chclry $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

16 Utilities $99,073.63 $1,093.49 $15,609.51

17 Healtll Care $16,054.15 $8,402.65 $16,370.66

18 Paypal $38,291.22 $810.37 $15,368.52

19 Venmo $27,437.14 $15,397.41

A complete list of all the vendors for the American Express purchases was compiled and the
vendors were contacted. A review of the expenditures revealed Jamey Noel charged $3 8,291.22,
Misty Noel charged $15,368.52, and Kasey Noel charged $810.37 on the American Express
Card for payments to .PayPal and Jamey Noel charged $27,437.14. and Misty Noel charged
$15,397.41 to Venmo. A11 the payments for the above charges to PayPal and Venmo, were paid
for by the Utica Township Volunteer Fire Fighters Association and I could not locate any
reimbursement by Jamey, Misty, or Kasey Noel.

On March 13, 2024, Indiana State Board of Accounts Special Investigator CPA Chris Sedam
provided me with a Utica Township Volunteer Fire Fighters Association Fifth Third Bank
Statement'showing an American Express payment of $38,168.63 on February 8, 2024. The notes
on the 5/3 Bank Statement indicate it was a "web-initiated payment". It is not clear ifJamey,
Misty, or Kasey Noel are still using the Utica Township Volunteer Fire Fighters Association
American Express Account. However, it appears charges were made on the American Express
Card linked to the UVFFA Account up to the end of January 2024.

ll
 Buslness Gold Rewards p.319
UTICA TOWNSHIPFF AS
JAMEY J NOEL
Closing Date 01129124 Account Ending-
(,P Customerfaresdiming Inquiries LBW-67840745
\Vabshe:amerita nuprezzcom
ifil International Coflm LESS-3934 l l I
l-8006750745
Lost or Stolen Card
Eton-:2 Cazh l ~BUO-CA5H-NOW CunamerCaIe Payments
1400—6784745 & Billing Inquiriex P0 EOX 6031
Large Print & Braille Statements
PDJOX 93l535 CAEOLSKRuu"MlL
A50. TX 50197-6031
799984535
Hearing lmpalred
Online chatat americanaxpresLcom or we Relay dial 7" and 1-800'675-0745

® We will debit your bank account for your monthly Autof'ay payment of
51.15.00 on 02/!3/24. This date may not be the same date your ban):
will debit your bank account. Any inquiry to American Express
concerning thlt debit should be made before 02/13/24. lfyour monthly
AutoPay payment is less than your Minimum Payment Due. we must
receive an additional payment for at leasuhe difierence by02/23124.

B For infomation on your Pay Over Time feature and limit. :ee page a

[ Payménts and Credits

I
Summary
Day In Full Day Over Time 9 Total
Payments $0.00 -S£J9.00 4149.00
Credits
JAMEYJ Mon. 47:03: 47.10.32 41,4015:
MlSTY NOEL- soon 435000 $50.00
KASEY NOEL $0.00 -$l 10.00 l woo

Total Paymenu and Credits 6740.82 61,649.82 62390.64

[ Detail unsuspenaqdm O
-dena:—.:Pny%n'me:a'vity]
Payment: Amount
ours/2r JAMEYJ NOEL AUTOPAY ramsmnzcavso-mmx you 440910
Fifth mm Bank NA
Credits < Amount
oimm- mun J NOEL poms camrr
AMAZON SHOP wrm 45°33
ainsrn- 1AMEYJ NOEL Immortsnopwrm POMSCEEDIT .3559};
exams was?) NOEL CREDITADJUS'IMENT 474022?
otnsm mm mm MED'NAPIES coumuumr Hos;- 053700000090 .szsoma
NAPLES FL
HOSPFI'AL
ems/2: KASEYNOEL ASSOCIATEINDERAMTOLOGYPLLC-W 4551304
CLARKSVME m
MEDICAL 55mm .

0111 m: KASEV NOEL Assocmas m osmuarmoov PLLC- max 4551,01

CLARKSVILLE m
LAFDII'AI m

Withdrawals I Debits 27 items totaling $537,828.53

Date Amount Descriptioti -

02/01 66025 U'nC-UTLOA TOWNS-MPOUND IMPOUND BIUJNG -

02/01 13.62800 .Insurance FBI EDI PYMNTS Township Volunte-
02/01 41,860.99 'MWUND IMPOUND
UTIC-UTIOA TOWNS
02/01 100,014.41 "PAYROLL 12952660 UTIC-UTICA TOWN -
EPAYROLL REDURC
02/02 5,985.43 LEASEDIRECTml'ICA TOWNSHIP FIRE DE INV# 587217405 DUE 02/01/24 REC:
02/05 44.18 Fleet E—Pay
02/05 1,487.92 RH FINANUAL SEHatcamoeuamey-
-
-
KS 5TF.TEELA.'*IK KSB Pl-'l'r UTK'A TOWNSHIP VOLUNTE
LEASECHG U'I'ICA TOWNSHIP VOLUME-4
02/05 5,112.64
02/07 2,410.00 .Utica
IN CHILD SUPPORT CHIID SUPPORT BUREAU WEBPAYMENT
WEB iNmATED PAYMENT AT AMEX EPAYt-lENTACJ-l PMT
Twp Vol Fxrefigh —
02/08
02/13
38,168.63
4,015.77
149.75
REV FINANCIAL Sis—n
Ul'IC-UIICA TOWNS—IMPOUND
'
BILUNG"
LEASEO-IG
IMPOUND
UTIOX TOWNSHIP VOLUNTE'
02/15 .

For additional iniomiation and account disclosures. please visit ww'.v.53.comlcommercialbanking Page 1 of 2

On March 19, 2024 I reviewed bank statements for Jamey and Misty Noel's three daughters, Kasey,
Josey, and Gracy Noel, and located Venmo/PayPal account activity for all three children.

12
Based on the above information I am requesting a search warrant for PayPal and Venmo records.

Conclusion:

I am currently investigating a ghost employment, tax evasion, theft, corrupt business practices
and official misconduct case involving fomler 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 35-44.1-1—
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. 1-1-1 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.

Alli of the above events occurred in Clark county, Indiana.

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

DATED: March 19, 2024 /s/ Lieutenant Jeffrey C. Hearon PE 5201 AFFIANT

13