Filed: 5/2/2024 10:03 AM

Clerk
ClarkSTATE
County, Indiana
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ISP CASE NUMBER 231$PC010364

SEARCH WARRANT 53

Probable Cause Affidavit

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

STATE OF INDIANA ) IN THE CLARK CIRCUIT COURT

) ss:
COUNTY 0F CLARK ) _
--

1N THE MATTER 0E ) CAUSE NUMBER:

A REQUEST FOR THE )
ISSUANCE 0E A ) 1oc01-2307-MC—001423
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:

A White iPhone 15 belonging to Jessica Huffman, located at the Indiana State Police
District 52 Temporary Cell Phone Evidence Storage Locker, 8620 East 215' Street
Indianapolis, Indiana, 46219.

The property or data to be 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:

Forensically examine the data contained on a White iPhone 15 belonging to Jessica

Huffman and search the device for digital data to include, but not limited to, photographs,
browser history, location data, social media apps, communication apps, call logs, contacts,
text messages (to include but not limited to SMS, MMS, iMessage), audio messages,
computer-related and/or electronic device documentation, records, and/or materials, e—mail
messages, voice mail messages, video files, audio files, data files, system files, multimedia

l
messages, stored phone books, contact lists and telephone numbers, call histories,
calendars, to-do lists, subscriber and/or owner(s) identifying information, social media data
and messages, any information on any user names, logins, screen names, e-mail addresses,
IP addresses, encryption or encrypted files, password(s), and/or electronic communication
used on the above-referenced listed iPhone 15.

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, law enforcement officer with the Indiana State Police, being
a
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 35-3l.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 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 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 County Sheriff from January l, 2015,
through December 31, 2022.

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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 and/or Bradley Kramer submitted fictitious Clark County Merit Deputy
Pension documents to allow Bradley Kramer, Sheriff Noel's brother in-law, to receive a
twenty-percent Merit Deputy pension to which he was not entitled.
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.

Colonel Grube explained, Sheriff Noel took office on January 1, 2015, and one of his first acts
was to promote Lt. Scott Conlen to Executive Director of Corrections, Sam Beard to Jail
Commander, and Lt. Mark Grube to Jail Investigator. According to Colonel Grube, Bradley
Kramer was a jail officer and was unknown to Sheriff Noel at the time he took office. Colonel
Grube indicated Bradley Kramer began to date and eventually married Jamey Noel's wife's sister
in 2016-2017.

Prior to 2018 Bradley Kramer was a jail officer and therefore was not eligible for a Clark County
Merit Deputy Pension. Bradley Kramer was promoted to Clark County Matron in 2018, which
made him eligible for the sheriffs pension program. Colonel Grube stated he believed Jamey
Noel intentionally altered promotion documents, and Bradley Kramer knowingly submitted the
documents, to receive an eight-year pension of twenty percent to which he was not entitled.
Colonel Grube provided me with two applications for pension purchase documents dated
09/17/2020 and 06/3 0/2020 and other supporting records. A review of the records indicated
many original reports had been altered.

I contacted former Clark County Sheriffs Department Human Resource Director, Phil Parker,
and questioned him regarding his interaction with Jamey Noel and Brad Kramer about the two
pension applications and other documents. Mr. Parker confirmed that he received two sets of
documents from Bradley Kramer and explained the first set appeared accurate and listed Bradley
Kramer's work history as being a jail officer for four years, and a matron and merit deputy for
the remaining time. According to Mr. Parker, the second set of application records and
supporting documents appeared to indicate Mr. Kramer was promoted to Clark County Jail
Matron on January 1, 2015, making him eligible for a twenty percent pension when Sheriff Noel
left office.

On April 2, 2024, Bradley Kramer consented to an interview and advised he was a jail officer
from January 6, 2014, to March 2018. He was then promoted to Merit Deputy and went through
a field training officer program and worked as a uniform road deputy until he was sent to the

3
Indiana Law Enforcement Academy in February 2019. He graduated from the ILEA in May
2019 and was assigned uniform patrol until August 2020 when he was promoted to Detective.

Mr. Kramer advised sometime in 2018 he was told by the Clark County Sheriff' s Department
Human Resource Director, Phil Parker, that Jamey Noel had promoted him to Clark County Jail
Matron. According to Mr. Kramer, Sheriff Noel repeatedly told him he had backdated the matron
promotion. Bradley Kramer was shown several documents indicating he was promoted to matron
on January 1, 2015. Mr. Kramer indicated the handwriting was not his on many of the
documents, his home address was incorrect, and he reiterated he was not promoted to matron
until 2018.

On April 29, 2024, I was reviewing text message communications between Jamey Noel and
Clark County Chief Deputy Auditor Jessica Lynn Huffman. The messages originated from one
of Jamey Noel's phones which was seized pursuant to a search warrant on August 16, 2023. The
seized phone was analyzed by the Indiana State Police Digital Forensic Unit and the text
messages where provided to me for review. The text thread appeared to indicate Ms. Huffman
provided Jamey Noel with a picture of an email from Colonel Mark Grube who was inquiring
with the auditor's office to determine when Bradley Kramer was promoted to matron.

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On April 30, 2024, Detective Chris Hanson and I spoke with Jessica Huffman at the Clark

4
County Auditor's Office. Ms. Huffman was asked why she provided Jamey Noel with a
photograph of Colonel Grube's email. Ms. Huffman indicated she was conducting her own
inquiry and wanted to see what Mr. Noel's reaction would be when he saw the email from
Grube. Ms. Huffman initially declined to allow a review of her text messages until she spoke
with an attorney. After speaking with an attorney, Ms. Huffman signed a consent to search
document allowing ISP to review the full text message thread between her and Jamey Noel. The
text messages appeared to indicate a three-year relationship between Jamey Noel and Jessica
Huffman, which included tickets to a Reds game, meeting for drinks at a Jeffersonville Bar, and
a detailed discussion regarding Bradley Kramer's appointment to matron. Additionally, there
appeared to be an ongoing exchange of information regarding the ISP and SBOA investigation
up to October 2023.

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I would like to ask for you

assistance on amending IC
36-2-7-10. Here is what I'm
for: We at the County Reco
Office charge a user fee for
recording surveys. The cod
we charge $35 and for any
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Jessica Huffman advised Jamey Noel had used other telephone numbers and communication
applications to communicate with her after October 2023, and those messages were possibly still
on her phone.

As a result of the above information and statements, I seized Jessica Huffman's white iPhone 15,
placed it into airplane mode to protect the data, and had it relayed to the ISP District 52 Cell
Phone Temporary Evidence Storage Lockers until I applied for a search warrant.

7
Based on the above information I am requesting a search warrant for the iPhone 15 belonging to
Jessica Huffman.

Conclusion:

I am currently investigating a ghost employment, tax evasion, theft, corrupt business practices
and official misconduct case involving former 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.

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.l-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.

All of the above events occurred in Clark County, Indiana.

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

DATED: May l, 2024 /s/ Lieutenant Jeffrey C. Hearon PE 5201 AFFIANT