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ISP CASE NUMBER 23ISPC'010364

SEARCH WARRANT 36
Probable Cause Affidavit

LIST OF PROPERTY, OBJECTS, THINGS, INFORMATION OR

PERSONS SEIZED OR PRODUCED AFFIDAVIT

STATE OF INDIANA I IN THE CLARK

) SS: . ,
COUNTY OF CLARK I CI CUL '1'

IN THE MATTER OF ~

) CAUSE NUMBER:
AREQUEST FORTHE ) -10 COL-3507' Alta-001423
ISSUANCE OF A )
SEARCH WARRANT )

Lieutenant Jeffrey C. Hearon, of the Indiana State Police Department, swears or affirnIs 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:

Mattingly-Ford Title Services, LLC, 4008 Northside Drive, Suite 1, New Albany, Indiana
47150 ' '

1
 fl"

W .un.'

The property to be searched, seized, or documented, whieh 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 property purchase documents/files, File number 1904213, title closing
documents, employment records, William Leon Noel Estate Documents, equity gift
documents, cancelled checks, and wire transfer documents related to the sale of 711 Old
Salem Road, Jeffersonville Indiana 4713.0.

2
STATEMENT 0F PROBABLE CAUSE

Afl'iant's Exnerience:

I, Indiana State Police Liéutenant Jefl'rey C. Heéron, being a duly swoi'n peace ofi'lcer for the
State of Indiana, have been employed by the Indiana State Police for 35 years.

Your affiant, Jefiey C. Hearon, a law enforcement officer with the Indiana State Police, being
duly sworn, swears and afirms 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 ofiicer 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 oficial 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 arn familiar with the techniques and methods of
operation used by individuals involved in criminal activity to conceal their activities fiom
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 afier current Clark County Sherifi'
Scott Maples reported several criminal allegations of Official Misconduct against former Clark
County Shefifi Jamey Noel. Jamey Noel was the Clark County Sherifl from January l, 2015,
through December 31, 2022.

I was directed to contactChief Deputy Sheriff Mark Grube for specific allegations and witness
information. On June 22, 2023, I contacted Chief Grube, and he advised there were several
allegations, some of which were as follows:

3
 o
Jamey Noel assigned four of the Claxk 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 sherifi', received millions of dollars in military surplus equipment, and he
and Kenneth Hughbanks acquired some of this property for their personal use.

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

On August l6, 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 Ofiicer, 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 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 had been
connected with the fire departments since the 1990's and held various Board and Officer
positions including Chief Executive Oflicer and Secretary and was responsible for a number of
'

the business filings and reports required by the Secretary of State's Oflice.

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.

Afier August 2023 several new board members were appointed, all of which work for one of
businesses entities associated with New Chapel Fire, Inc., or Utica Township Volunteer Fire
Fighters Association. The Board of Directors were Jamey Noel, Matthew Owen, Paul Holcomb,
and Shannon Grant. One of the first acts of the new board was to sign a facility use agreement,
allowing Jamey Noel to lease his Pole Barn at 709 Old Salem Road, Jeffersonville, Indiana to the

4
Utica Township Volunteer Fire Fighters Association, in exchange for the corporation paying the
utilities and improvements among other considerations.

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 F ire
Department (below), is estimated at approximately eight to nine milion dollars, of which
approxirnately two million is tax dollars or public funds.

____.

IN BIZ .]
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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
afiiliated 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 and 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.

Additionally, I learned that Kasey Noel was appointed 'as Jamey Noel's administrative assistant.
A Kasey Noel W-2 Tax document found during one of the search warrants indicates Kasey Noel
received approximately $77,888.00 for 2022.

During this investigation I obtained tax records, bank records, and property records for Kasey
Noel. A review of the property records indicate Kasey Noel owns the following properties:

l. 71 l Old Salem Road, Jefiersonville, Indiana 47130

5
 I discovered Kasey Noel had a mortgage on the property from'United Wholesale Mongage LLC.
I subpoenaed the mortgage records and determined the 711 Old Salem Road home was originally
owned by William "Leon" Noel, Jamey Noel's deceased brother and uncle to Kasey Noel. I
learned Leon Noel passed away on Friday, December 21, 2018, at Jewish Hospital in Louisville.

Leon Noel had three surviving children which were the heirs of his estate, Dorian Noel age 23,
'

Taylor Noel age 19, and.

Noel age 11. Jamey Noel was appointed as executor of Leon's
estate, which consisted of a 5/3 Bank Estate Account, the house and property at 711 Old Salem
Road, and a house Leon purchased to "flip" located at 413 Glenview Heights, New Albany,
Indiana.

The mortgage records indicated the closing for the 711 Old Salem Road property was held on.
April 26, 2019. The house was sold to Kasey Noel for $180,000.00. As executor of the estate,
Jamey Noel gave/gifted Kasey $36,000.00 of equity. The closing was completed at Mattingly-
Ford Title Services, LLC, which has an office at 4008 Northside Drive, Suite 1, New Albany,
Indiana 47150.

Afier the mortgage was paid ($112,000.00), closing expenses were deducted, and Kasey Noel
was gifted $36,000.00, a check for $25,545.78 was issued to the Estate of William Leon Noel.
The check was deposited in the 5/3 William Leon Noel Estate Account administered by Jamey.

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A review of the 5/3

Estate Bank Records and information from the Momentum Title Company
'show the 413 Glenview Heights property was sold for $119,687.79 on May 29, 2019, and the
proceeds were deposited in Leon's 5/3 Estate Account.

The 5/3 Estate Bank statements and cancelled checks indicate Jamey Noel paid Paul Lockhart
Construction $8000.00 by a check from Leon's Estate Account and two $8232.30 payments via
PayPal, which were linked to the Utica Township Volunteer Fire Fighter Association American
Express account for basement work on the Glenview Heights property.

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'On May 29, 2019, arney Noel wrote himself a check for $16,000.00 for basement
reimbursment, however he did not provide any personal payment but instead charged the
UTVFFA for the basement payments and profited $16,000.00 .

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On June 5, 2019, Jamey Noel paid $19,117.45 to Scott Funeral Home for Leon's funeral
expenses.

0n October 23, 2019, Jamey Noel, as estate executor, distributed $29,574.53 to Dorian Noel.

On December 2, 2019, Jamey Noel personally withdrew $52,504.00 fiom William Leon Noel's
Estate Account.

. On December 26, 2019, Jamey Noel wrote two checks for $36,989.02 to Taylor and. Noel.
The checks bounced due to insufliciant funds.
'

. .

On January 15, 2020, Jamey Noel withdrew $52,500.00 fiom the Utica Township Fire Fighter
Association Account and deposited it into the William Leon Noel Estate Account.

8
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On January 15, 2020, Jamey Noel obtained two cashier's checks for Taylor and-Noel for
$36, 989.02 and closed the account

It appears Jamey Noel profited $68,552.00 and Kasey Noel profitted $36,000.00 from monies
taken from William Leon Noel's Estate. Additionally, it appears Dorian, Taylor, and.Noel
failed to receive $36,000.00 in inheritance because of equity given to Kasey Noel.

On January 17, 2024, I contacted Mattingly-Ford Title Services, LLC and requested copies of the
closing paperwork for the sale of William Leon Noel's 711 Old Salem Road residence, including
any documents gifting Kasey Noel $36,000.00 of equity. I was advsied by Russell Ford he would

9
 need a court order to produce the documents.

Conclusion:

I am currently investigating a ghost employment, tax evasion, thefi, corrupt business practices
and official misconduct case involving former Clark County Sheriff and former Utica Volunteer
Fire Fighters Association, Chief Jamey Noel, Misty Noel, 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 Thefi, 35-44.1-2-2 Obstruction of Justice, 35-45-6-2 Corrupt
Business Influence, and 35-44.1-l-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 of the above events occurred in Clark County, Indiana.

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

DATED: February 6, 2024 /s/ Lieutenant Jeffi'ey C. Hearon PE 5201

AFFIANT

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