Filed: 2/22/2024 1:39 PM

Clerk
Clark County, Indiana

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1-513 CASE NUMBER ZBISPC010364

SEARCH WARRANT 42
Probable Cause

LIST OF PROPERTY, OBJECTS,ITHINGS, INFORMATION OR

PERSONS SEIZED OR PRODUCED AFFIDAVIT

STATE OF INDIANA I IN THE CLARK CIRCUIT COURT

) ss:
COIJNTY OF CLARK )

IN THE MATTER OF ) CAUSE No. 10c01-24o7-Mc-00001423

A REQUEST FOR THE )
ISSUANCE OF A )
SEARCH WARRANT )

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

J
Jamey and Misty Noel's Ohio River Mansion, 2408 Turnberry Drive, effersonville,
Indiana 47130, historically known asithe "Captain John Hoffman House".

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The property to be searched, 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:

Inspect and seize the 3-ton HVAC Bryant Heat Pump, serial number 1323x33702, installed
0n May 3," 2023, and paid for with Utica Township Volunteer Fire Fighter Association
funds and the following GE Appliances receipts, warranty documents, and, delivery and
installation documents for said appliances:

Two black GE induction cooktops.

V'PP'P?'

GE White countertop microwave.

GE Stainless steel double walled oven.
GE Stainless steel French door refrigerator.
GE Ice Maker

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 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 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:

3
 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.
'

0' 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 J amey 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.

l requested assistance from the Indiana State Board of Accounts in conducting an audit on the
Clark County Sheriff's Department, Utica Township Volunteer Fire Fighter Association, Utica
Fire DepartmentIncorporated and the other assumed named businesses associated with
UTVF FA. Three forensic accountants and a supervisor were assigned to my investigative team.
Additionally, I requested and received an Indiana Department of Revenue Field Agent to assist
in the investigation.

As part of the audit process conducted by Indiana State Board of Accounts Investigators, an audit
was performed on the Clark County Sheriffs Department Commissary Fund. On January 25,
2024, Indiana State Board of Accounts investigators located an invoice dated July 20, 2022, from
Miller Heating and Cooling for $6,539.12. The invoice indicated the replacement of the existing
heating and cooling system at 1800 Patrol Road, Charlestown, Indiana. The address returned to
the Charlestown Volunteer Fire Department, which is run by Utica Fire Department, of which
Jamey Noel was the Chief. The invoice was paid for by the Clark County Sheriff s Department
Commissary. I contacted the owner of Miller Heating and C001ing, John Miller Junior, who
provided an original invoice. I compared the original invoice to the one submitted by Jamey Noel
to the commissary and noticed the one submitted to the commissary fund had an altered billing
address. Mr. Miller indicated he installed the HVAC system at the Charlestown Fire Department
and not at the Clark County Sheriff's Department.
 '

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On January 26, 2024, a search warrant was obtained and executed at the Charlestown Volunteer
Fire Department located at 1800 Patrol Road, Charlestown, Indiana. The 92% HVAC 100,000
btu gas fiJrnace with 4 Ton AC Unit, serial number 4421E15240, listed on the above invoice was
found and documented. Since the leadership had terminated Jamey Noel as Chief the decision
was made to not seize the HVAC unit.

On February 15, 2024, I obtained and reviewed additiOnal invoices from Miller Heating and
Cooling and noticed an invoice for 2408 Turnberry Drive, J effersonville, Indiana 47130 dated
May 3, 2023, for the purchase and installation of a Bryant 3 Ton Heat Pump. I contacted Miller
Heating and Cooling and was advised Jamey Noel paid for the heat pump with check number
14471. I located a copy of the check and verified the check was written on the Utica Township
Volunteer-F ire Fighter Association Fifth Third Bank Account.

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On February 16, 2024, I recontacted Miller Heating and Cooling and was advised the serial
number for HVAC Unit installed at 2408 Tumberry Drive, J effersonville, Indiana 47130 was
1323X33702.

3 —_.;TME.I?"..LER Date
5/3203
Invoice
Invoice #
240688
4..., age? Tenns

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am T'q Due on receipt.
Jamle Noels
2408 Tumber Dr.
Jeffersonville. In 471 30

Phone #
Locallon PO Invoice Typo Rep
2408 TURNBERRY DR 2408 H VAC HJM
Descrlpuon

To replaoe existing heat pump unlt and to Install a 3 Ton heat pump with all materlals and
labor
TOTAL DUE $2700.00
Bryant Equipment

Thank you for your business

E-mail
A finance charge of! .50% month!) for' Invoic- not paid by duc dale or l8% annually

check us out on the If ,_

6
During this investigation; I was made aware Jamey and Misty Noel Were the owners of the
"Captain John Hoffman House" mansion located at 2408 Turnberry Drive, J effersonville,
Indiana 47130. I obtained the tax records from the Clark County Assessor's Office and a review
of those documents revealed Jamey and Misty Noel purchased the Mansion on October 5,2022,
'

fer $699, 000. 00

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On February 20, 2023, State Board of Accounts Field Examiner James Donoho observed a
charge of $16,885.63 on theUtica Township Volunteer Fire Fighter Association American
Express Card issued to Jamey Noel from Appliance Connection. He contacted Appliance
Connection, and they provided the below invoice. The invoice indicated Jamey Noel received the
following appliances delivered to the 2408 Tumberry Residence on September 18, 2022:

1 Two black GE induction cooktops.

2 GE White co'untertop microwave.
3 GE Stainless steel double walled oven.
4 GE Stainless steel French door refrigerator.
GE Ice Maker.

7
Appliance Connection Invoice
Order Number

10655742

Thank you for your order!

Dear JAMEY NOEL,

Thank you for your order. Your patronage is very much appreciated. We hope you received your
order in a satisfactory manner. Please carefully inspect the contents and condition of your
merchandise upon receipt. If you have any questions, please feel free to call us. We are always
ready to serve you the most professional manner. If you opted for an extended warranty, it will
be pre-registered, but you will need to log-in online to cemplete the registration within 30 days
of receiving your item(s). If you find any damages at the time of delivery, please contact us at
"immediately.
Ship To: Bill To:
JAMEY NOEL .
JAMEY NOEL
3001 Old Tay Bridge
2048 Tumberry D nve Jeffersonville, IN 47130
JEFFERSONVILLE, W 47130
'
PAID IN FULL
Email: car1chief©aol.com Payment MethodzAmerican Express
Phone: 5026394973 Financing Terms:

Shipping Method:A&M Trucking: White Glove Delivery

Description Price Qty Total

1.GE Profile Black Induction Cooktop (PHP903ODJBB) $1,992.00 2 $3,984.00

I
Estimated Return charge if unopened within 30 dayS' $135.00 Estimated pick-rip fee for exchange
]
if unopened within 30
days: $7.50

2.GE Profile White Countertop Microwave (PEM31DFWW) $399.00 1 $399.00

]
Estimated Return charge if unopened Wllhln 30 days: $49.50 Estimated pick-up fee for exchange if unopened within 30 dayS'
1

S24 75

3.Express Delivery Appliance Accessories (EXDV) $69.99 1 $69.99

]
Estimated Return charge if unopened within 30 days. $0.00 Estimated pick-up f~e for exchange if unopened within 30 days.
|

80 00
4.Concierqe Service Appliance Warranties (CONCIERGESERVICE) $49.99 3 $149.97
I
Estimated Return charge if unopened within 30 days: $0.00] Estimated pick—Lip fee for exchange if unopened Within 30 days:
$30.00

5.Professional Service Appliance Installation (COOKTOPINSTALL) $0.00 2 $0.00

]
Estimated Return charge if unopened within 30 days: $0.00 Estimated pick-up fee for exchange
|
it" unopened within 30 days.
$0.00

6.Deliverv Options Appliance Removal (RM1AB $0.00 2 $0.00

I
Estimated Return charge it unopened within 30 dayS' $0.00 Estimated pick-up fee for exchange if unopened within 30 days.
|

sc- so

7.GE Profile Stainless Steel Double Wall Oven (PK78008KSS) $3,992.00 1 $3,992.00
1
Estimated Return charge if unopened within 30 days: $337.50 Estimated pickup fee for exchange if unopened within 30
|

days: $168.75

8.GE Profile Stainless Steel French Door Refrigerator $3,773.00 1 $3,773.00

(PVDZBBYN FS)
1
Estimated Return charge if unopened within 30 days: $637.50 Estimated pick—up fee for exchange if unopened within 30
days: $318.75

9.GE Profile Panel Ready Ice Maker (UNC15NPRII) $3,413.00 1 $3,413.00

I
Estimated Return charge if unopened within 30 days: $214.50 Estimated pick-up tee for exchange it unopened within 30
day's: $107.25

10.Professional Service Appliance Installation $0.00 1 $0.00

(DOUBLEWALLI NSTALL)
'

]
Estimated Return charge it unopened within 30 days. $0.00 Estimated pick-up fee for exchange it unopened within 30 days.
I

50 00

11.Delivery Options Appliance Removal (RM1 BIO) $0.00 1 $0.00

Estimated Return charge if unopened within 30 days $0.00 Estimated pick-up fee for exchange if unopened within 30 days'
|

$0.00

SUBTOTAL $15,780.96
DISCOUNT' $0.00
SHIPPING $0.00
TAX $1,104.67
Total2 $16,885.63

9
 J
I am requesting a search warrant be issued for 2408 Tumberry Drive, effersonville, Indiana to
inspect and seize the Bryant 3 Ton Heat Pump, serial number 1323X33702 and the above listed
GE Appliances, receipts, warranty documents, and delivery and installation documents.

Conclusion:

I am currently investigating a ghost employment, tax evasion, theft, corrupt business practiCes
and official misconduct case involving former Clark County Sheriff and Utica Township
Volunteer Fire Fighters Association former Chief Jamey Noel and his 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, 6-3-6-11 Tax Evasion, and 35-44.1-1-1 Official Misconduct and 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 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: February 20, 2024 /s/ Lieutenant Jeffrey C. Hearon PE 5201

AF FIANT

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SEARCH WARRANT 42
LIST OF PROPERTY, OBJECTS, THIN GS, INFORMATION OR
PERSONS SEIZED OR PRODUCED

STATE 0F INDIANA ) 1N THE CLARK CIRCUIT COURT

SS
COUNTY OF CLARK )
CAUSE NO 10C01-2407—MC-001423

IN THE MATTER OF
))))

A REQUEST FOR THE

ISSUANCE OF A
SEARCH WARRANT

Law enforcement offlcer(s) are hereby authorized and ordered, in the name of the State of
Indiana, with the necessary and proper assistance, to execute the search warrant attached to this
List of Property, Objects, Things, Infdrmation or Persons Seized or Produced ("LiSt") and search
the business more particularly described as follows:

Jamey and MistyNoel's Ohio River Mansion, 2408 Turnberry Drive, Jeffersonville,
Indiana 47130, historically known as the "Captain John Hoffman House".

11
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The property to be searCh, 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:

Inspect and seize the 3-t0n HVAC Bryant Heat Pump, serial number 1323X33702, installed
on May 3, 2023, and paid for with Utica Township Volunteer Fire Fighter Association
funds and the following GE Appliances and receipts, warranty documents, and delivery
and installation documents for said appliances:

6 Two black GE induction cooktops.

7 GE White countertop microwave.
GE Stainless steel double 'walled oven.
9. .
GE Stainless steel French door refrigerator.
1 0. GE Ice Maker

This Search Warrant and Affidavit, and attached and incorporated Statement of Probable
Cause and associated attachments were sworn to as true and subscribed before me on this
day of , , at A.M. / P.M.

l2
Wherefore, I'find probable cause for the issuance of this Search Warrant and do issue it.

ORDER APPROVED: YES NO

(Signature)
Judge

13