Filed: 5/9/2024 8:45 AM

Clerk
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ISP CASE NUMBER 231$PC010364

SEARCH WARRANT 55

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 OF CLARK )

IN THE MATTER OF ) CAUSE NUMBER:

A REQUEST FOR THE ) l 0C01 —2307-MC-00 1423
ISSUANCE OF A )
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:

The Clark County Chief Deputy Auditor's Office assigned to Chief Deputy Auditor Jessica
Huffman, 300 Corporate Drive, Suites 105 & 106, Jeffersonville, Indiana 47130

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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 folloyvs:

Seize and examine any and all documents, files, notes, calendar and other hard copy files,
and seize and forensically examine any and all electronic devices believed to be capable of
creating, storing or transmitting digital information, images and/or communications
located in the office, or in control of Jessica Huffman. Such devices include but are not
limited to: any and all computers, cell phones, tablets, and/0r external digital storage
devices located on the property and search those devices 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/0r
materials, e-mail messages, voice mail messages, video files, audio files, data files, system
files, multimedia 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 any of the above-referenced items in association.
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 affirIns 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 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.

I was directed to contact ColonelMark 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:

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 o Jamey Noel and/0r 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 l, 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 NoelYs 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. x,

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
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

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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 swn
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 201 8.

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 J arney 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 were provided to me for review. The text thread appeared to indicate
Ms. Huffman
Mark who was inquiring
provided Jamey Noel with a picture of an email from Colonel Grube,
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
County Auditor's Office. Ms. Huffman was asked why she provided Jamey Noel with a
her own
photograph of Colonel Grube's email. Ms. Huffman indicated she was conducting
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
Huffrnan, which included tickets to a Reds game, meeting for drinks at a J effersonville Bar, and
a detailed discussion regarding Bradley Kramer's appointment to matron. Additionally, there
appeared to be an ongoing exchange of information regarding the investigation.

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Jessica Huffman advised Jamey Noel had used other telephone numbers and communication
applications (software 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.

On May 2, 2024, a search warrant to search the data contained in Jessica Huffman's iPhone 15
was granted and ISP Digital Forensic Unit Sergeant Chris Howell successfully downloaded the
data contained in the phone. A review of the data indicates Jamey Noel and Jessica Huffman
communicate through several different apps including Snapchat and WhatsApp. Both apps are
used to send text, voice messages, share images, Videos, and documents. Additionally, Jessica
Huffman set up a Snapchat "My Eyes Only" passcode protected folder. My Eyes Only is a
digital folder which allows the user to move Snaps, pictures, videos, and stories into a protected
who administer the apps found
folder: Multiple preservation orders were sent to the companies
on Jessica Huffman's phone.

A review of the iPhone 15 indicated there were more than 100,000 images/photographs saved on
the phone. A review of some of the photographs indicate Ms. Huffman has been/using her Clark

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County credentials to access various databases containing personal information related to former
and current Clark County Sheriff Department Employees, including a former employee Russell
Garrison, which contained social security numbers and other personal information.

Additionally, it appears Jessica Huffman met frequently with Jamey Noel, and would take
photographs while the two of them were visiting Jamey Noel's historic mansion located 2408
Tumberry Drive, J effersonville, Indiana.
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A more comprehensive review of the text messages between Jessica Huffman and Jamey Noel
was conducted, and it appears Mr. Noel provided Ms. Huffman with gifts and assistance for her
future run for political office.

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Based on the above information I am requesting a search warrant be granted for Jessica
Huffman's Clark County Office, documents, and data contained on her computer.

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 hiswife 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 35-44.1-1-
3 Ghost Employment, 35- 43 -4—2 Theft, 35-441 2- 2 Obstruction of Just1ce 35- 45— 6- 2 Corrupt
Business Influence, 35- 44. 1- l- l Official Misconduct, and 6-3-6-11 Tax Evasion property related
to the commission of said felonies.

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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 7, 2024 /s/ Lieutenant Jeffrey C. Hearon PE 5201 AFFIANT

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