Filed: 7/24/2024 3:39 PM

6 mr.
Clerk
Clark.4County, Indiana
cf/ \Q.
—
4

REDACTED kl'
Ill.

ISP CASE NUMBER ZBISPC010364

SEARCH WARRANT 63

Probable Cause Affidavit

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

STATE OF INDIANA i [N THE CLARK

ss
01 Val/(1LC
f v
) 2

COUNTY OF CLARK i

[N THE MATTER OF ) CAUSE NUMBER:

AREQUEST FOR THE ) (DA/)1" 2307'm 4—1433
ISSUANCE OF A -

)
SEARCH WARRANT )

Lieutenant Jeffrey C. Hearon, of the Indiana State Police Department, swears 0r 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:

Southwest Airlines
Attention: Legal Department
2702 Love Field Drive
Dallas, Texas 75235

The property or data to be seized or documented, which constitutes unlawfully obtained

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

Any and all billing and account information including but not limited to the following: flight
history, reservation information, Subscriber information, purchase history, statements,
wire transfers,
payment history, including canceled checks, bank account numbers,

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

1. Jamey John Noel

3001 Old Tay Bridge, Jeffersonville, Indiana 47130

Gender: Male

2. Brittney J. Ferree

Gender: Female

3. Misty Alena Noel

3001 Old Ta Bridge, Jeffersonville', Indiana 47130

4. Kasey Alexander Noel

J
3001 Old Tay Bridge, effersonville, Indiana 47130

STATEb/IENT OF PROBABLE CAUSE

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

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

am a police officer with the Indiana State Police. l have been a police officer with the
Indiana
I
is defined in Ind.
State Police since 11/ 13/1988. I am a "law enforcement officer" as that term
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 I988. I
have satisfied 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
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.

Iwas 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 ajoint taskforce consisting of investigators from the Indiana State Police, Indiana State
Board of Accounts, Indiana Attorney General, Department of Defense Investigators, and Indiana
Department of Revenue. Approximately forty—two subpoenas and sixty-two search warrants were
iSSued.
On August l6, 2023, I fanned 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
Volunteer Fire Fighters
profit board minutes, and financia records for the Utica Township
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.

copies of the Utica Township Volunteer Fire Fighters Association (UTVFFA)

I obtained 1954
Articles of Incorporation, UTVFFA Amended Articles of Incorporation 1993, UTVFFA
Application for Reinstatement 1993, and the UTVFFA Indiana Secretary
of State Business
The various Articles of
Entity Report 2022 listing Jamey Noel as the Chief Executive Officer.
State indicate that Jamey Noel has been
Incorporation and reports submitted to the Secretary of
connected with the fire departments since the 1990's and has held various Board and Officer
and was responsible for a number of
positions, including Chief Executive Officer and Secretary,
the business filings and reports required by the Secretary of State's Ofiice.

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During this investigation I contacted the past and present listed board of
directors and determined
in several years, and the members
prior to August 2023 there had not been a board meeting
indicated Jamey Noel had acted independently absent board participation, but he was never
authorized to purchase personal items, trips, timeshares, jewelry, personal vehicles, and pay his
funds.
personal property taxes and utilities with not-for-profit

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
to eight million dollars. Total public
Department (below), is estimated at approximately seven
funds received by New Chapel EMS, for the SBOA examination period 2019 to 2023, were
$3,886,388.80.
 During the period of this examination, New Chapel EMS received a total of $3,886,388.80 61 public
funds from Clark and Floyd counties.

Clark Floyd
Year County County Totds

2019 $ -
$ 177,222.23 5 177,222.23
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 $ 1,057,22219 $ 3,886,388.80

During the execution of the search warrants on August 16, 2023.1 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 and other card holders. A review of the charges made
by Jamey Noel revealed many were for personal purchases and suspected to be evidence of thefi
and tax evasion.

Below is a breakdown of Jamey Noel's American Express purchases per year.

Jamey Noel:
WMMWWMIMMWEMSMEMSMM
Category 2019 2020 2021 2022 2029 Totals

41cm 5 Tobacco ' s 11,401.46 6 12,296.19 3 24,915.35 3 16,566.46 3 6,111.56 5 71,921.02

46:06:19 582.15 -
7,396.65 51.62 2,198.23 16231.45
Airman and mum-6016 36,264.64 26,1 14.72 16,036.72 36,113.69 45.69241 149,636.24
Beauty Products and 0161111119 16,240.96 10,161.41 6,646.14 12,521.65 3,231.06 62,636.64
0191131 Med: and We 4.37226 6,241.16 3,264.96 2,956.14 3,966.51 20,665.06
Donatlons ' 667.60 7,656.04 1,477.60 20,646.52 2,577.50 33,238.06
6mm 6,062.47 123.01 226.00 1,249.00 1,730.67 9,361.35
6111mm: Movies, 666116,
Em, Cancun: '
-

12,600.06 10,016.14 6,011.21 16,6n.72 11.26625 58,790.32

qupmem -
Was, Phones,
pm Accasmes 5,416.63 7,215.96 1,593.23 3,062.15 3,106.90 26,515.07
Food 63,069.90 46,040.16 47,164.40 64,427.46 34,045.96 27,367.92
Gas 91m 4,415.97 3,707.61 6.174.40 4,065.56 5,252.46 22,616.19
4 Healh Care Pmessms
116111111 9,737.32 207.34 2,716.74 1,544.75 1,717.46 15,923.63
Fumlme and Home 1111mm 49,947.44 30,662.16 11,611.99 26,613.69 22.67024 202,665.54
hsunnce 2, 139.61 2,561.00 9,914.45 3,906.67 22,665.53 4-1,n6.12
maul 13,199.41 1 1,246.15 13,176.24 16,253.96 1 3,376.52 69,266.30
1
Jewelry 11,063.30 -
1,012.00 44,635.00 -
56,970.30
Memoasmn and service Pea 543.62 551.14 1,066.36 726.54 493.60 3,320.56
Mobile Payment ' 31,663.77 21,514.15 45,299.92 53,612.47 1 1,466.21 163,176.52
961:4 Slots and 01111116 W 0069s '
413,206.67 117,664.66 62,616.12 61,015.96 51,499.90 366,479.95
Taxes 20,061.31 6,165.62 17,415.06 16,651.76 31,725.92 94,639.95
1111697111114 Sm ' 46,330.41 62,162.34 62,749.55 72,167.22 37,741.47 323,171.66
omer 21,526.04 5,316.66 14,243.03 12,114.46 4,219.21 51,543.60
uunues 17,451.91 16,952.33 16,766.06 21,604.92 17,507.66 94,464.96

16121: 3 401,417.41 6 425,662.61 $461,417.02 3 515,673.60 9341.19491 9 2,164,965.61

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

Child support payments to Britteny Ferree:

During this investigation, I became aware Jamey Noel was in a romantic relationship with
Brittney Ferree, a Clark County Councilwoman, from January 1, 2019, to December 31, 2022.
As a result of the relationship, Brittney Ferree gave birth to a child. A check of the Indiana
MyCase Data Base System cause number 10C04-2002«JP—000028, indicated Mr. Noel was the
father of Brittney Ferree's male child and he was ordered to pay child support.

A review of the American Express charges indicated several child support payments. I requested
and obtained a subpoena for the Indiana Child Support Bureau for Jamey Noel's child support
payments. I was provided approximately 154 pages of child support documents, copies of
cancelled checks, and a one-page history of American Express Credit Card child support
payments. An examination of the payment history revealed Jamey Noel paid many of the child
support payments using Utica Township Volunteer Fire Fighters Association funds. Below is an
example of one of the checks.

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A State Board of Accounts Audit indicated between March 31, 2020, to November 29, 2021,
Jamey Noel wrote 21 checks drawn on the UTVFFA Fifth Third Bank Account for child support
to Brittney Ferree for their child. The 21 checks totaled $50,968.00.

Between January 1, 2022, to September 1, 2023, Jamey Noel made 22 charges to the UTVFFA
American Express Card to pay for child support to Brittney Ferree for their child. The 22 total
American Express charges plus American Express Credit Card Convenience Fees were
$54,003.51.

6
 Category Amounts

Check Payments $ 50,968.00

Credit Card Payments 52,815.07
Credit Card Comenience Fees 1,188.44

Total Child Support Payments $ 104,971.51

Theft of UTVFFA BMW and sale to Brittney Ferree:

r.

During this investigation I obtained Indiana BMV Records for all vehicles owned by the Utica
fl
.I

Township Volunteer Fire Fighters Association. A review of those records indicated Jamey Noel
sold a 2015 BMW, owned by UTVFFA, to Brittney Ferree for $21,000.00 on January 21, 2023.
An interview with New Chapel EMS Deputy Director Matt Owen revealed Jamey Noel
deposited $23,000.00 cash on August 21, 2023, into the UTVFFA Fifih Third Bank Account,
and claimed the money was from the sale of the BMW to Brittney Ferree. It should be noted the
deposit was made after search warrants were served at JameyNoe'l's residence and pole barn on
August 16, 2023.

On December 28, 2023, a search warrant was obtained for Brittney Ferree's residence to
photograph the 2015 BMW and collect other items of evidence. Brittney Ferree provided a
recorded statement indicating she gave Jamey Noel $21,000.00 cash for the purchase of the 2015
BMW and she was unaware the child support payments were coming from UTVFFA.

7
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Vehicle T e GER

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CURRENT OMER "FORMATION

Lend Venue? No
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Purchase Dale 01'2112023
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Theft of UTVFFA Funds totaling $6,998.40 given to Brittney Ferree:

On March 20, 2024, I obtained and served Search Warrant 47 for Jamey Noel's PayPal and
Venmo Records. A review of those records indicated four payments to HeadPlay Salon, owned
by Brittney Fence, Jeffersonville, Indiana, by Jamey Noel. The charges were as follows:
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The payments totaling $6,998.40 were made to Brittney Ferree by Jamey Noel via PayPal using
Utica Township Volunteer Fire Fighters Association Funds.

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Investigation into Jamey Noel and Brittney Ferree traveling to New York, New Orleans,
and Tampa using Utica Township Volunteer Fire Fighters Association Funds:

Further review of the American Express charges indicated that Ms. Ferree and Mr. Noel went on
at least three trips together, which are as follows:

10
RecoVered records indicate Jamey Noel and then Councilwoman Brittney F erree traveled to New
York City and stayed at the Roosevelt Hotel on April 23, 2019. Records indicate Brittney Ferree
flew on Delta Airlines.
.
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On May 27, 2022, Jamey Noel and Brittney Ferree traveled to Tampa, Florida Ms. Ferree was
also accompanied by her daughter Remington, and they flew on Southwest Airlines. The tickets
were, paid for using UTVFFA funds.

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On July 28, 2022 Brittney Ferree and Jamey Noel traveled to New Orleans, and Brittney flew on
Breeze Airways paid for by UTVFF A funds.

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On January 18, 2024, I obtained and reviewed a Memorandum of Agreement for Emergency
Medical Ambulance Service in Clark County, Indiana. The Memorandum, among other things,
for ambulance services. The
provided New Chapel EMS with $700,000 a year funding
in
Memorandum was approved on October 1, 2020, and three subsequent appropriations requests
were approved by the Clark County Council in October 2020, May 2021, and November 202
1.
Councilwoman Brittney Ferree was not present for the October 2020 initial appropriation request
but voted in the affirmative during the May and November 2021 appropriation requests.

12
 MEMORANDUM or: AGREEMENI
[QR EMERQxENCY MEDICAL AMBU LANCE SERVICE
m CLARK CQUNTY, running
'

This Memorandum ofAgreeritent Emergency Medical Ambulance Service in

re'gardiynfi day of October. 2020, by and betwem the
Clark County, Indiana is entered into on this i
Board of Commissioners of Clark County, In tuna (the "County"? and New Chapel EMS ("New
Chapel"). and the said Parties agree as follows:

I. That New Chapel shall provide Emergency Medical Ambulance Service

shall provide six (6) ambulances for county-
throughout Clark County, lndiana. New Chapel
wide service as follows:

0 One (1) ALS Ambulance strategically located for CharlestownINew Washington

District

0 One (,I) BLS Ambulance strategically located for Jeffersonville District 4/5 and Utica
Twp. District

0 Two (2) ALS Ambulances strategically located Em- Iel'l'eraonville Districts "213

0 One (1) ALS Ambulance strategically located for the Clarksville District

- One (I) ALS Ambulance strategically located for the Sellersburyfiorden/Monroe

District
for emergency
2. That the six (6) assets stated above will be reserved primarily
In addition to these primary emergency assets. New Chapel will also provide
response only.
numerous l0, [2. and 24-hour assets available for unforeseen times
of peak call volume. These
are BLS and ALS units which can be pulled from pro-scheduled non-emergmcy transports as
administrative and to
needed. Additionally, New Chapel will cross-train their supportostnff
provide greater scalability if necessary.

That New Chapel shall be paid a one (I) year subsidy of $700,000
to provide
3.
Medical Ambulance Service to Clark County, lndlana as set forth above. The annual
Emergency
installments due on or before the last day
subsidy shall be payable in twelve (12) equal monthly
with the first monthly installment for October due on or before
of each month, beginning
October 3t, 2020 and the final monthly installment due on or before September 30, 2021.

4. That the initial term of this Agreement shall be for a one (I) year period,
on October l, 2020 and ending on Septunbel' 30, 2021. That the term
of this
beginning
or modified as mutually agreed-to by the Parties.
Agreement may be extended

and inquired if
On June 25, 2024, I spoke with Clark County Council Attorney Maxwell McCritc
Mr. McCritc advised he provided all
Brittney Ferrec completed a conflict-of—interest document.
council members with a conflict-of—intcrest document and is not aware Brittney Ferret:

completed one. Mr. McCrite provided an example

of the document he sends to council members.

13
 WORK CWUCTOF areas." MOLDIURE IITATEIEIIT
I— a."
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Kin-Imma-

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am?" d Matias: maxim ammu- m
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sum "with:' mu
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orndmdm We" miukflumd Warm
.:
them
dammit!)
mmdayflcmata awamwmm(zmhblt4—2—
rummaging! Srinagar!"
MMMMGMWEWWIN
"914%
m m W denafismnMI-I-L
I.

2. Muwmww
1 I. Wait}:
a. candy:
L
ml" m
a._ Wm
":1!"be umu
WMmUMIWMU
hairy: "an; lumen;
n_ mm mm: in m
man:
amt!dummguinl'mmnmum
s. mpumum-

a
mmwmammamtmm. mwtw
Ismail. lwzmmwmwm;

In total, Jamey Noel gave Brittney Ferree approximately $114,070.00 in Utica Township
Volunteer Fire Fighters Funds for child support, trips, and other expenses.

On July 23, 2024, I reviewed the American Express charges for Southwest Airlines and
determined that Jamey Noel spent approximately $9,362.93 using Utica Township Volunteer
Fire Fighters Association Funds.

On July 3, 2024, I requested, received, and executed Search Warrant 57 for Allegiant Air
records. On July 23, 2024, I received an 80-page document from Allegiant Air indicating Jamey,
Misty, Kasey, Josey, Gracy, and extend family and friends traveled to numerous destinations. A
review of the receipts revealed a total of $60,153.05 was spent on airfare.

Based on the above information, I am requesting a search warrant for the records of purchases
and flights for Brittney Ferree, Jamey, Misty, and Kasey Noel from Southwest Airlines, which
7

does business in the state of Indiana.

l4
Conclusion:

and official
I am investigating a ghost employment, tax evasion, theft, corrupt business practices,
misconduct case involving former Clark County Sheriff} fonner 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

above facts, l have probable cause to believe, and do

analysis of the data. Therefore, based on the
believe, that evidence of the commissions of felonies, in violation(s)
of Indiana Code 35—44.l-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—44.1-1-1 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 bestof my
knowledge and belief.

All of the above events occurred in Clark County, Indiana

I sWear (affirrn), under penalty of perjury as specified by IC 35-44-2-1, that

the foregoing

representations are true.

DATED: July 23, 2024 /s/ Lieutenant Jeffrey C. Hearon PE 5201 AFFIANT

15