STATE OF FLORIDA CASE NO. 

COUNTY OF ALACHUA 

AFFIDAVIT FOR CRIMINAL COMPLAINT 

1. I am a Special Agent with the Bureau of Alcohol, Tobacco, Firearms and 

Explosives (ATF), and have been so employed for 11 years. Prior to being an ATF agent, I was 

a District Security Officer for the United States Marshal Service and a Juvenile Correctional 

Officer for the State of West Virginia. I also served in the United States Army as an Enlisted and 

Commissioned Officer. I served in combat deployments in Iraq and Afghanistan. I currently 

hold the Rank of Captain and serve as a "Medevac" Blackhawk Pilot in the Army Reserves. 

2. I am currently assigned to the A TF Tampa Field Division, Gainesville Satellite 

Office. My responsibilities as a Special Agent include, among other things, conducting 

investigations involving violations of Titles 18, 21 and 26 of the United States Code. As a 

Special Agent I have investigated violations of federal fuearms and narcotics laws and have 

helped execute numerous arrest and search warrants. 

3. I have attended the Federal Law Enforcement Training Center (FLETC) in 

Glynco, Georgia, where I received instructions in the recognition, identification, and prosecution 

of violations of federal laws. 

4. I have written this affidavit to show that there is probable cause to support a 

criminal complaint against Curtis Woods Jr. Because this affidavit is made for the sole purpose 

of providing probable cause to support a complaint, I have not included every detail of my 

investigation, but only those facts necessary to establish probable cause to believe Woods has 

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violated 18 U.S.C. 922(g)(l) by possessing a firearm and being a previously convicted felon 

convicted of a crime that was punishable by imprisonment for more than one year. 

5. The statements made in this Affidavit are based, in part, on my personal 

knowledge, and other information furnished to me through discussions with other persons 

including deputies from the Alachua County Sheriffs Office (ASO) and the Gainesville Police 

Department (GPD). This affidavit is intended to show only that there is sufficient probable cause 

for the requested warrant and does not set forth all of my knowledge about this matter. 

PROBABLE CAUSE 

6. On July 21 , 2019 ASO Deputies were dispatched to 6133 SW 10th PL, 

Gainesville, FL in reference to shots being fired. When Officers arrived they were met by 

Horace Hicks. Hicks advised that a black male known to him as "Whoa" had driven up to his 

residence and fired three shots at him from a Burgundy SUV. The vehicle was driven by a 

female known to the witness as Sylvia. Hicks advised that he was seated in the front driver's 

seat of a vehicle bearing tag number Z203LG. Hicks advised that once Whoa started shooting he 

dropped to the ground and crawled to the back of his vehicle. Hicks described Whoa to ASO 

deputies and advised he had just gotten out of prison. Hicks pointed out Whoa from a Facebook 

profile "Rico Swavai" . This photo was sent to ASO deputies which identified Whoa as Curtis 

Lee Woods Jr. A photo lineup was compiled and presented to Hicks. Hicks immediately 

identified Curtis Lee Woods as the same suspect that had fired shots at him. 

7. ASO Forensic units were called to process the scene. There were bullet jackets 

that were located in the trash can in front of the driver side door. There was an entry hole but no 

exit hole in the trash can. There was also a bullet jacket that was located behind the front left tire 

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of Hick's vehicle. There was also what appeared to be bullet impacts on the wall located behind 

the passenger side of the vehicle. 

8. A witness Frankie Velez stated to ASO Deputies that he observed a burgundy 

vehicle drive up to the location and fire 3 shots towards 6113 SW 10th Pl. Velez stated the 

firearm was fired from inside the vehicle. Velez described the shooter as a 20-25 year old black 

male with short hair. 

9. While ASO was conducting the investigation Hicks stated that he had also been 

shot at on July 20, 2019 by Whoa. Hicks stated that he believed Whoa was trying to kill him due 

to a recent feud with one of his friends. Hicks stated that on July 20, 2019 Whoa shot at his 

white Buick sedan with a handgun and struck the rear window. The location of this incident was 

1300 SE 23rd Ave Gainesville, FL. Officers observed that Hicks's rear window had been 

knocked out. Officers observed this in Hicks's rear seat area. Due to the second shooting being 

located in the city GPD was notified and followed up on that shooting. For a more detailed 

account of this incident please see ASO report ASO 19OFF006856. 

10. I reviewed the GPD Reports and the following facts were stated. While 

investigating the Horace Hicks's attempted murder it was learned that Curtis Woods had fired 

shots at Hicks's on two consecutive days. GPD Officers interviewed Hicks and he stated that on 

July 20, 2019 he was confronted by Whoa in the city of Gainesville. Hicks stated to GPD that he 

was leaving work when he noticed a small burgundy SUV driving in front of him. Hicks stated 

that Whoa is known to drive that SUV. Hicks advised that Whoa is involved in an ongoing 

dispute with Mario Lamar whom he is friends with. Hicks stated that he pulled up next to the 

SUV and opened his driver's door. Hicks advised that Whoa exited the driver's seat of the SUV. 

Hicks advised he yelled to Whoa, "What's your beef with Lamar?" Hicks advised that Whoa 

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pulled out a handgun and started to run towards him. Hicks stated that he quickly ducked his 

head and accelerated his car. Hicks advised he heard a gunshot and noticed the back window of 

his vehicle was shot out as he was driving away. Hicks advised he did not contact LEO until the 

second shooting because he did not want to get Whoa in trouble. Hicks advised that after the 

second shooting he wanted to document the shooting from the day prior. For a more detailed 

account of this incident please see GPD report 02-19-0119 5 5. 

11 . On July 28, 2019 GPD Officers responded to another incident involving a firearm 

and a death threat by Curtis Woods Jr. GPD Officers responded to 1600 SE 4th St Gainesville, 

FL and spoke with victim Andre King. King advised that he was engaged in a verbal argument 

with his ex-girlfriend. King advised he then saw his ex.:girlfriend and a man pull up in her 

vehicle as he was walking to the store on the 1600 block of SE 4th St. King advised that the man 

exited the vehicle and pointed a black and grey semiautomatic handgun at him. The man then 

told King "Nigga I' 11 kill you! " while pointing the handgun at King. The man then struck King 

in the upper left side of his face with the butt of the firearm. King stated the man again pointed 

the gun at him stating again that he would kill him. King identified Curtis Woods out of a 6 

person photo lineup as the man that pointed a gun and threatened him. King refused to sign the 

photo lineup due to fear of retaliation from Woods. 

12. Due to the multiple firearms incidents a warrant was issued for Curtis Woods. I 

was made aware of the multiple firearms incidents by ASO and GPD officers. On July 29, 2019 

officers were attempting to execute an arrest warrant for Curtis Woods for attempted murder of 

Horace Hicks, possession of a firearm by a convicted felon, and discharging a firearm from a 

vehicle. Officers received information that Woods was staying at Motel 6 located at 7413 West 

Newberry Road. Officers conducted surveillance of the hotel and determined that Woods was 

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staying in room 233. Officers wearing vests identifying themselves as Sheriff and US Marshals 

attempted to make contact with Woods. Woods fled on foot and ignored commands by law 

enforcement to stop. 

13. While officers were chasing Woods he ran to an approximately 15 foot concrete 

wall. As officers approached they observed Curtis Woods throw an object over the wall. Woods 

them attempted to throw other items over the wall. Woods did not comply with Officers as they 

attempted to arrest him. Officer immediately searched the area Woods was observed throwing 

items to. Officers recovered a loaded black and grey Smith and Wesson semiautomatic handgun 

from the area Woods threw an object. The firearm was loaded with a round in the chamber and 

additional rounds in the magazine. Woods refused to speak with Officer Post Miranda. 

14. I was made aware of the multiple firearms related cases involving Curtis Woods 

in a short timeframe. I drove to ASO and spoke with the evidence section. I learned that 

fingerprints of value had been lifted from the firearm. I requested a comparison be made 

between the fingerprint found on the firearm in ASO property and Defendant Curtis Woods Jr. I 

was notified that Latent Print Examiner John Swartz made a positive identification from the 

firearm recovered during the arrest of Curtis Woods Jr. The results of the comparison was Lift 

number 3 from the top area of the slide resulted in a positive match to right palm of Curtis Lee 

Woods Jr. 

15. I have received certified copies of prior felony convictions for Curtis Lee Woods 

to include 2009 Alachua County Aggravated Battery with a Deadly Weapon and Robbery with a 

Deadly Weapon, 2014 Alachua County Aggravated Assault with a Deadly Weapon, Possession 

of Firearm by a Convicted Felon, 2016 Alachua County Possession of a Firearm by a Convicted 

Felon, and False Imprisonment. 

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16. The Smith &Wesson pistol was manufactured outside of the State of Florida and 

recovered within the State of Florida, thus it has travelled in and affected interstate commerce. 

17. Based on the foregoing, I respectively submit that there is probable cause that the 

defendant, CURTIS LEE WOODS Jr., unlawfully possessed a firearm and ammunition, in 

violation of Title 18, United States Code, Section § 922(g)(l ). 

Bureau of Alcohol, Tobacco, Firearms, and Explosives 

Sworn to and subscribed before me this 3rd day of September 2019. 

The H::iro: A:: 

United States Magistrate Judge 

Northern District of Florida 

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