Misty Noel, the wife of indicted former Clark County Sheriff Jamey Noel, has been charged with 10 counts of tax evasion and theft.

1. FILED QC.© -QN_F5'03°
""3 ' 2023 REDACTED
AFFIDAVIT
FOR PROBABLE CAUSE
STATE 0F INDIANA, COUNTY 0F CLARIg ss: Agency case report: 231src010364 -
The Amant, Indiana State Police Lieutenant Jeffrey C. Hearon swears (affirms) that:
0n June 13, 2023, I was assigned a criminal invesfigation afier current Clark County Sherifi'
Scott Maples reported several criminal allegations of Official Misconduct against former Clark
County Sherifl Jamey Noel. Jamey Noel was the Clark COunty Sherifl fiom Jannary l, 2015,
through December 31, 2022.
I was directed to contact the ChiefDeputy Sheriff Mark Grube for specific allegations and
witness information On June 22, 2023, I coutacted Chief Grube, and he advised there were
several allegations some of which were as follows:
o
Jamey Noel assigned four ofthe 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 bam, 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 shen'fi', received millions of dollars in military surplus equipment and he
and Kenneth Hughbanks acquire some ofthis property for their personal use.
I formed a joint taskforee Consisting of investigatdrs fiom the Indiana State Police, Indiana State"
Board ofAccounts, Indiana Attorney General, Department ofDefense Investigators, and Indiana
Depamnent ofRevenue. Approximately forty-two subpoenas and thirty-five search warrants
were issued
On August 16, 2023, I formed four teams of detectives, uniform troopers, an Indiana Department
ofRevenue 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 land 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.
l

2. I obtained copies of the Utica Township Volunteer Fire Fighters Association (UTVFFA) 1954
Articles of Incorporation, U'I'VFFA Amended Articles ofIncorporation 1993, UTVFFA
Application for Reinstatement 1993, and the UTVFFA Indiana Secretary ofState Business
Entity Report 2022 listing Jamey Noel as the Chief Executive Officer. The various Articles of
Incorporation and reports subitted to the Secretary ofState indicate that Jamey Noel has been
connected with the fire departments since the 1990's and held various Board and Officer
positions including ChiefExecutive 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.
Afier August 2023 several new board members were appointed all ofwhich 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, Mathew Owen, Paul Holcomb,
and Shannon Grant. One of the first acts ofthe 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
Utica Township Volunteer Fire Fighters Association in exchange for the corporation paying the
utilities and improvements among other considerations.
With the assistance ofIndiana State Board ofAccounts, the total annual income for all the above
businesses and New Chapel Fire INC, which is an assumed business name for Utica Township
Volunteer Fire Fighters Association (below), is estimated at approximately 7 to 8 million dollars
ofwhich approximately two million is tax dollars or public funds.
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Indiana Code 36-8-1'1 allows for a county legislative body to establish fire protection districts in
each ofthe 92 Indiana Counties. For the purposes ofthis 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.
2

3. 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 2010-12. 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 ofthe annual contracts have changed throughout each year but confirmed the 2022
contract was approximately 1.2 million dollars.
'
During this investigation I obtained tax records, bank records, and property records for Jamey
and Misty Noel. The bank records indicate Jamey and Misty Noel have several joint bank
accounts which are used by both parties. A review ofthe property records indicate Jamey and
Misty Noel jointly own me following properties: .
l. Indiana Home, 3001 Old Tay Bridge Road Jeffersonville, Indiana.
2. Historic Queen Ann Mansion "Hoffinan House" 2408 Tumberry Drive Jeffersonville,
Indiana.
3. Rental Property, 722 Court Street Jefi'ersonville, Indiana.
'
4. Pole barn, cabin and apartment 709 Old Salem Road Jeffersonville, Indiana.
5. Florida Home 516 Eagle Creek Drive, Naples, Florida.
The business records, vehicles registrations, financial records, and information revealed above
were shared with Indiana Department ofRevenue Agent Rick Albrecht. Agent Albrecht provided
the following information:
On August 14, 2023, on November 03, 2023, and on January 12, 2024, Agent Rick Albrecht
assigned to Criminal Investigations Unit, Indiana Department ofRevenue searched the revenue
database for Jamey J. Noel and Misty A. Noel 3001 Old Tay Bridge, Jeffersonville, Indiana
47130. The review, on each date showed Jamey J. Noel and Misty A. Noel filed an Indiana
Individual income tax retum, Form IT-40 with the State ofIndiana for the year ended 2018, -
2019, 2020, 2021 and 2022. The returns were filed as a married return filing jointly.
On August 16, 2023, search warrants were executed at the residence ofJamey J. Noel and Misty
A. Noel. Among the various documents seized by police during the execution of the search
warrant was the 2018 federal income tax retum, Form 1040. The retum states it was self-
prepared meaning either Jamey J. Noel or Misty A. Noel or both of them together prepared the
2018 federal income tax return, Forrn 1040 and the Indiana individual income tax retum, Form
IT-40. The Indiana individual income tax return, Form IT—40 begins with the federal adjusted
gross income as reported on the federal income tax return, Form 1040.
The federal adjusted gross income reported on the federal Form 1040 consists in part ofthe
following sources of income: Wages, business income or loss from Schedule C, capital gain or
loss fiom Schedule D, rental ofreal estate, royalties, S corporation income, and fann income.
On the 2018 federal income tax return, Form 1040 ofJamey J. Noel and Misty A. Noel they did
report wages fi'om the W-2 form in the amount of $255,672 and reported a capital gain fiom the '
sale ofreal property in the amount of$537. The wages of$255,672 and the capital gain of$537
equals the adjusted gross income reported on the Form 1040 of $256,209. The 2018 Indiana
3

4. individual income tax return, Form IT-40 begins with the federal adjusted gross income of
$256,209 which was reported on the federal income tax remm, Form 1040.
The examination ofthe federal return Schedule 1 showed Jamey J. Noel and Misty A'.>No_el
reported a capital gain of$537. The examination of Schedule D, Capital Gains and Losses states
'
Jamey J. Noel and Misty A. Noel sold property for $236,500. The cost of that property to Jamey
J. Noel and Misty A. Noel was $153,463 and they had an adjustment to the sales price of
$82,500. The result of the sales price less the purchase price and adjustment left a capital gain of
$537 which was reported on Schedule 1 of the Form 1040. Form 8949 of the federal Form 1040
reports the sale ofsix properties. (l) 306/309 Locust Street On the form Jamey J. Noel and
Misty A. Noel state the property was acquired November 06, 2013, and sold June 28, 2018. The
sales price ofthe property was $6,000 and the basis ofthe property was $5,463.12. The gain on
the sale of 306/309 Locust Street was $536.88 which when rounded up is the $537 capital gain
reported on the Form 1040. (2) MVC Destinations. The property was obtained September 24,
2013, for $44,550 and was sold September 24, 2018 for $44,550 for no gain or loss. (3) MVC
Destinations. The property was obtained September 24, 2013, for $33,950 and was sold
September 24, 2018 for $33,950 for no gain or loss. (4) MVC Destinations. The property was
obtained September 24, 2013, for $24,600 and was sold September 24, 2018 for $24,600 for no
gain or loss. (5) Main Home Sale -
203 W. Main Street. Jamey J. Noel and Misty A. Noel state
the property was purchased June 13, 1996, and sold on September 13, 2018. The property was
sold for $82,500. The cost or other basis of the property is shown as $0. The $82,500 is u'eated
under the home exclusion and the $82,500 is not heated as a capital gain, the gain is excluded
fiom income tax. (6) Main Home Sale —
508 West Market Street. The property is shown as
being purchased July 13, 2015, and sold February 05, 2018. The property is reported as having a
sales price of$44,900. The cost or other basis in the property is shown to be $44,900. The
property does not show a gain or loss.
0fthe six properties reported on Forrn 8949 ofthe Form,1040 only one property showed a gain,
306/309 Locust Street, which had a gain of $537. Four ofthe properties were sold for the
purchase price or other basis in the property and they had no gain or loss. 203 W. Main Street
was sold with a profit of $82,500. This profit was excluded under the home sale rule. The home
sale exclusion is explained in IRS Publication 523. Sale of your main home. In order to take the
home sale exclusion an individual must live in the residence for two of the last five years prior to
the sale.
On the Form 8949 Jamey J. Noel and Misty A. Noel stated they purchased 203 W. Main Street
June 13, 1996, and sold the property September 13, 2018. The Clark County Indiana Recorder's
Office states Ronald W. Jackson sold 203 W. Main Street, Henryville, IN to Jamey Noel on May
23, 2017. The Clark COunty Indiana Recorder's office states Jamey J. Noel and Misty A. Neel ,
sold 203 W. Main Street, Henryville, IN to Megan Howe on September l3, 2018. Jamey J. Noel
and Misty A. Noel did not have the right to claim 203 W. Main Street, Henryville, IN as their
primary residence and did not have the right to exclude fi'om income the $82,500 as a gain fi'om
the sale of their primary residence.
In 2014 Jamey J. Noel and Misty A. Noel purchased 3001 Old Tay Bridge, Jeffersonville, m. In
2014 Jamey J. Noel and Misty A. Noel took the Homestead Credit for 3001 Tay Bridge,
4

5. Jeffersonville, 1N. An Indiana resident may only have the Homestead Credit on his principle
residence. Indiana Code 6-1.1-12-37 states in part, "Homestead" means an individual's principal
place ofresidence that is located in Indiana, which the individual owns. Jamey J. Noel and
Misty A. Noel owned and lived at 3001 Tay Bridge, Jefi'ersonville, IN fiom 2014 to the present
Jamey I. Noel and Misty A. Noel did not purchase 203 W. Main Street, Henryville, IN until May
23, 2017 and they sold that property September 13,2018.
When Jamey J. Noel and Misty A. Noel filed a false federal income tax return, Form 1040 they
then filed a false Indiana income tax return, Form IT-40 because the Indiana return begins with
the federal adjusted gross income. Jamey J. Noel and Misty A. Noel falsely filed the federal
Form 1040 when they knowingly reported the gain on 203 W. Main Street, Henryville, 1N to be
exempt under the home sale exclusion. Jamey J. Noel and Misty A. Noel knowingly filed a false
Indiana income tax return, Form 1T-40 for the year 2018 when they knew the federal adjusted
gross income fi'om Forrn 1040 that begins the Indiana tax return, Form IT-40 was false because
they knew the sale of203 W. Main Street, Henryville, 1N was not their main residence and was
not allowed the home exclusion treatment. Jamey J. Noel and Misty A. Noel violated Indiana
Code 6-3-6-11 by knowingly filing a false Indiana income mx return, Forrn 1T-40 for the year
2018.
For the year 2019 Jamey J. Noel and Misty A Noel filed the Indiana individual income tax
retum, fonn IT-40 as required by Indiana Code Title 6. Jamey J. Noel and Misty A. Noel
reported federal adjusted gross income of $256, 664. This income is from wages reported on the
W-2 fonn. Jamey J. Noel and Misty A. Noel failed to report income fiom the sale ofa 2019
Challenger SRT Hellcat to the Utica Township Volunteer Fire Fighters Association (UTVFFA).
Jamey Noel traded a 2017 Chevrolet 3500 Silverado that was OWned by UTVFFA for a 2019
Challenger SRT Hellcat. The Hellcat was then titled in the name Jamey Noel. On October 10,
2019 Jamey Noel sold the Hellcat to UTVFFA for $83,716. The income from this transaction
was not reported on the income tax return, FormIT-40 as required by IC 6-3-6~11. For the year
2019 Jamey J. Noel and Misty A. Noel failed to report $83,716 in taxable income.
For the year 2020 Jamey J. Noel and Misty A. Noel filed the Indiana individual income mx
return, form IT-40 as required by Indiana Code Title 6. Jamey J. Noel and Misty A. Noel
reported federal adjusted gross income of$291,745. This income is'from wages reported on the
W-2 form. Jamey J. Noel and Misty A. Noel failed to report income from child support
payments that were made from the bank account ofUTVFFA in the amount of $22,160. Further
Jamey J. Noel and Misty 'A. Noel failed to report a payment made fiom the bank account of
UTVFFA for swimming, pool repairs at their residence in Naples, Florida, 516 Eagle Creek Drive
totaling $6,802. For die year 2020 Jamey J. Noel and Misty A. Noel failed to report $28,962 in
income derived ficm the bank account ofUTVFFA.
Jamey Noel was ordered to make child support payments to Brittany Ferree for their child, John
Ferree. Jamey J. Noel made these payments from funds owned by UTVFFA and failed to report
the conversion ofthese funds as taxable income to himself(Jamey J. Noel). Jamey J. Noel and
Misty A. Noel contracted with Anglers Services, Inc. to complete work on a swimming pool at
their residence in Florida, 516 Eagle Creek Drive, Naples, Florida. Jamey J. Noel converted
funds owned by UTVFFA for the payment owed on the swimming pool in the amount of$6,802.
5

6. For the year 2021 Jamey J. Noel and Misty A. Noel filed the Indiana individual income tax
retum, form IT-40 as required by Indiana Code Title 6. Jamey J. Noel and Misty A. Noel
reported federal adjusted gross income of$334,704. This income is fiom wages reported on the
W—2 form and retirement income reported on form 1099R. Jamey J. Noel and Misty A. Noel
failed to .report income fiom child support payments that were made fiom'thebank account of
UTVFFA in the amount of$28,808. These payments were converted fi'om the bank account of
UTVFFA for the benefit ofJamey J. Noel and Misty A. Noel. The payments were made for the
benefit ofJamey J. Noel's child, John Ferree. Jamey J. Noel and Misty A. Noel failed to report
$92,000 fiom the sale/trade ofa Chevrolet Corvette. On May 03, 2021 Jamey Noel traded the
2020 Chevrolet Corvette owned by UTVFFA for a 2020 Mercedes-Benz S-Class 450. The value
ofthe Chevrolet Corvette was $92,000. Values ofthe 2 vehicles were similar. The 2020
Mercedes-Benz S-Class 450 was registered in the name Jamey Noel. Jamey J. Noel converted
property owned by UTVFFA, a 2020 Chevrolet Corvette and traded it for the Mercedes for his
own purposes and failed to report those monies as taxable income.
For the year 2022 Jamey J. Noel and Misty A. Noel filed the Indiana individual income tax
return, forrn IT~40 as required by Indiana Code Title 6. Jamey J. Noel and Misty A. Noel
reported federal adjusted gross income of$352,883. This income is from wages reported on the
W-2 form and retirement income reported on form 1099R. Jamey J. Noel and Misty A. Noel
failed to report income fi'om child support payments that were made fiom the bank account of
UTVFFA in the amount of $3 1,201. These payments were converted fiom the bank account of
UTVFFA for the benefit ofJamey J. Noel and Misty A. Noel. The payments were made for the
benefit ofJamey J. Noel's child, John Ferree. Further, Jamey J. Noel and Misty A. Noel failed to
report $102,500 fi'om the sale of three additional vehicles.
On August l3, 2022 Noel converted property owned by UTVFFA, a Kubota HST Tractor by
selling this vehicle to James Bishop for $31,000. The funds from this transaction were deposited
'
to the bank account cfJamey Noel. On April 20, 2021 Jamey J. Noel traded a vehicle owned by
UTVFFA, for a 2012 Porsche Panamera. The Porsche was titled in the name Jamey Noel. 0n
September 12, 2022 the Porsche was sold for $32,000. The fiinds were deposited into the bank
account of Jamey Noel. On December 02, 2020 Jamey Noel traded a vehicle owned by
UTVFFA for a 1957 Chevrolet Bel-Air and titled the Bel-Air in the name Jamey Noel. On
September 27, 2022 Jamey Noel sold the Bel-Air to Kenny Hughbanks for $39,500. The funds
from this transaction were deposited into the bank account ofJamey Noel.
In 2018, 2019, 2020, 2021 and 2022'Jamey J. Noel converted property ofUTVFFA, motor
vehicles, to his own use and received at least $278,216 and they failed to report any of that
income on the Individual income tax return, Form 1T-40 of Jamey J. Noel and Misty A. Noel.
For the years 2020, 2021 and 2022 Jamey J. Noel took funds from the bank account of UTVFFA
to pay child support payments in the amount of $82,169 and they failed to report any ofthat
income on the Individual income tax return, Form 1T-40 of Jamey J. Noel and Misty A. Noel.
Jamey J. Noel converted property and money ofUTVFFA and used it for his own purposes and
they failed to report those funds as income on the Indiana individual income tax return, Form IT-
40 ofJamey J. and Misty A. Noel.
6

7. During the execution ofthe search warrants on August l6, 2023, I found several American
Express receipts indicating Jamey Noel had at least one credit card account. On September l4,
2023, a subpoena was sent to American Express for all accounts associated with Jamey Noel. On
January l8, 2024,~American Express sent the following summary:
(1) American Express has identified concerning activity on Business Gold charge card
account number associated 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 Novemberlé, 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 is not the intended use ofthe 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 aeeOunts. Internal records indicate the Business Gold card
account was opened in January 2011, 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 ofspend for an OPEN business card associated with a non-profit and
raises concerns about misuse. Spend was primarily conducted at for 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 fighter 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 Fighter 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. 0n January 25, 2024, American Express provided 1729 pages
ofcharges, payments, and statements associated with the Jamey Noel, Misty Noel, Kasey Noel,
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Matthew Owen (UTVFFA Board Member), and Kevin Wilkerson (UTVFFA Board Member).
A review of the 2018 to 2022 records considered for tax evasion charges indicated the following
charge amounts per year were made by Jamey and Misty Noel:
EL! m ml w York
m $29,669.34 $137,257.04 suggest" smamsa $144,535.33 $600,142.04
Janey. s7l.s7s.l l $91,231.62 s51 moan $626,292.74 $657,401.30

8. Below is a breakdown ofJamey and Misty Noel American Express purchases per month and
year (February 5, 2019, to August 18, 2023) used for the purposes oftheft charges.
0 4043 '00 an
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, 2913 1Q! .
2921 my.
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January 5 0,001.90 $ 12,079.72 5 5,025.00 5 11,033.43
February 3 4,495.00 3 3,030.70 3 12,520.50 3 5,500.03 5 10,503.49
March 3 0,000.70 3 10,340.33 0 15,931.43 5 11,530.10 5 14,013.30
April 3 10.30031 3 0,391.93 3 0,531.35 3 13,300.03 3 14,713.33
May 5 11,021.20 5 13,057.33 5 3,790.00 3 10,353.14 3 10,351.70
June 3 0,500.90 5 12,200.01 3 0,039.47 $ 11,550.70 3 11,113.27
July $ 11,410.17 3 12,120.09 3 12,000.90 3 13,050.32 3 10,041.34
August 3 13,434.41 3 12,037.24 3 0,373.33 5 10,073.15 3 0.51934
54mm 5 11,332.72 5 11,711.13 3 0,323.50 3 11.75340
'
October 0 19.13304 3 13,240.31 5 11,702.90 5 14,993.23
Nombor s 15,317.23 3 14,904.07 3 10,710.35 5 10,133.51
December 3 17.03000 5 21303.70 5 20,531.05 3 10,300.53
Mammals 149,200.14]; 130,920.04]; 144,300.00[$ 9502200115 660,806.6fl
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
Fighter Association.
American Express provided a detailed payment and purchase history. An analyses 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.
mm 2919 2211 mg m1 Lou as: 19.13
unuary s 30,309.00 0 40,190.41 5 25,452.10 3 34,903.73 5 10,679.01
February 5 40,503.23 5 23,020.72 5 02,472.00 5 44,400.97 3 55,935.05
March 5 14.40001 5 33,545.59 $104,294.75 5 30.57079 3 50,300.01
April .3 49,329.90 5 40,727.21' 5 40,520.40 5 45,025.90 $106,660.35
my $ 57,131.20 3 49.25900 5 64,061.43 5 03,705.01 5 54,103.10
lune s 20,957.01 3 29,211.00 5 07.35000 5 43,144.19 5 00.05033
July $ 20,417.10 $40,323.00 $ 20,439.00 5 49.10909 5 35,370.01
AW 3 24.743.12 $ 03,504.00 5 44,034.90 3 50,745.49 5 30,030.05
September 5 30,370.11 5 49,903.70 $59,900.51 5 79,927.37 9 15,405.00
October $20,095.39 5 22,510.93 $ 41,330.13 539.12301 s 02,240.75
November 5 24.99293 3 20.02022 5 20,995.20 $ 33,071.14 5 44,010.04
December 5 25,009.79 5 72,315.03 9 47,290.90 5 30.94002 5 90,550.21
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
Fighter Association. ,
American Express provided a detailed payment and purchase history. An analyses ofthe records indicated
Jamey Noel made purchases forclothing, 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.
rs 11,573.11] $491,182.62 I s 511,408." I 5 $25,291.74] $551,401.30 [$39,119.11 1 $ 2,857,682.71]
8
:

9. Jamey J. Noel and Misty A. Noel received income they failed to report to the Stave of Indiana,
Department ofRevenue totaling $3,413,892.69 during the years 2018, 2019, 2020, 2021 and
2022. This is a yiolation of Indiana Code 6-3-6-11.
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Conclusion:
I am currently investigating a ghost employment, tax evasion, thefl, corrupt business practices ,
and oficial misconduct case involving former Clark County Sheriff and current Utica Volunteer
Fire Fighters Association, Chief Jamey Noel, his wife Misty 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 ofRevenue 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 ofthe data. Therefore, based on the above facts, I have probable cause to believe, and do
believe, that evidence ofthe commissions of felonies, in violation(s) ofTax Evasion Indiana
Code 6-3-6-11 and Theft Indiana Code 35-43-4-2.
9
Source 2018 7
2019 2020 2021 2022
of
imam:
Sale of
hope"
$82,500
Sale of $83,716
Hellcat
Child $22,160 $28,808 $31,201
Sale of
vehicle
$102,500
5
Cost of $6,802
Com
Pool
e sale
$92,000
Amen
Mistyfs $29,669.34 $137,857.04 $149,208.14 $138,920.64 $144,586.88
an
S
Exptu
c as
Jamey'
3
$71,578.11
'
$497,282.62 $511,408.38 $626,292.74 $657,401.80
Americ
an
Expre-
;°"" For 5 years Not reported $3,413,892.69

10. I declare under penalty ofperjury that the foregoing is true and correct to the best ofmy
knowledge and belief.
All ofthe above events occurred in Clark County, Indiana
I swear (affirm), under penalty ofperjury as specified by 1035-44-24, that the foregoing
representations are true.
DATED: January 30, 2024 /s/ Lieutenant Je C. Hearon PE 52 l
AFFIANT
10