Filed: 4/21/2023 3:07 PM

St. Joseph Superior Court 1

St. Joseph County, Indiana
STATE OF INDIANA ) IN THE ST. JOSEPH SUPERIOR COURT
) SS:
COUNTY OF ST. JOSEPH )
)
STATE OF INDIANA )
)
VS ) AMENDED
) SUPPLEMENTAL AFFIDAVIT IN
TREYVEON MAURICE MOORE ) SUPPORT OF PROBABLE CAUSE
DOB: 5/18/2003 )

Detective Kyle Bilinski affirms under the penalty of perjury and states:
I am a law enforcement officer employed by the South Bend Police Department for the past 10

years where I am a Detective in the Violent Crimes Unit and make this affidavit after having knowledge of

the investigation, speaking with other officers, and reviewing police reports.

On 06/06/2022, South Bend Police responded to the area of Marshall/33rd St. reference a shooting.

When officers arrived, they located male suffering from apparent gunshot wounds laying in the front yard

of a residence in South Bend, IN. The male was identified as Curtis Shelby and he was pronounced
deceased at the scene. An autopsy later confirmed that Shelby was killed by a single gunshot wound.

Witnesses at the scene observed the victim wearing a red hoodie being walked down the street by two

other males, one of whom was wearing a yellow shirt. The three men walking were followed by three

vehicles, one of which was a White Ford Fusion. A witness known by police disclosed that the shooter
was seen wearing yellow. Witnesses heard arguing and then observed the man in yellow shoot at the man

in red (Curtis Shelby).

During the course of the investigation there was evidence found that Curtis had stolen a vehicle a

few days earlier and was attempting to sell the vehicle that night. Evidence from social media/digital
evidence was uncovered that a group of individuals known by police had gone to meet with Curtis that

night to obtain the vehicle by force. One of those individuals was TREYVEON MOORE.

A source known by police (Witness 1) came forward with information about the homicide.
Witness 1 stated that an involved party in the incident had personally disclosed information to them.

Witness 1 stated that MOORE was asking them if they knew who Curtis Shelby was, and then MOORE
stated that MOORE had shot Curtis Shelby. MOORE provided specific details about the location and also
said that it was reference a stolen car. MOORE stated that Curtis was “walked” down a street, and that

MOORE shot Curtis in the back. Video surveillance recovered from the area corroborated MOORE’S
statements.

Officers obtained a warrant for MOORE’S cell phone call detail records. These records contain

location data. Location data placed MOORE’S device in the area of the homicide at the time of the
homicide. MOORE’S Icloud data was also obtained which contained text message content. Messages

were found from the night of June 6, 2023 referencing MOORE going to get the car back, that they made

fake accounts to trick Curtis Shelby in to meeting them, that they weren’t going to call the police, and

were going to fight.

On 04/19/2023, a search warrant was granted to obtain a DNA standard from MOORE. MOORE

was located and detained for the execution of the search warrant and for questioning. I advised MOORE

of his Miranda warning and he agreed to speak with me. During that interview, MOORE initially stated

that he was aware of Curtis Shelby’s death and knew the group of individuals that were present and was

familiar with the facts, however MOORE stated that MOORE was not involved or present during the
homicide. When confronted with the cell phone location evidence, MOORE changed his story and

admitted that he was present at the scene of the homicide with the group to beat up Curtis and take the

stolen vehicle. MOORE stated that they had arranged to meet Shelby at a gas station. After Curtis Shelby

walked away from the gas station, they all proceeded to beat Curtis up and individuals took Curtis’s

cellphone and wallet from his person. Following that beating, they walked/followed Curtis down the street

where the stolen car was allegedly parked. MOORE stated that as they approached an intersection, Curtis

took off running and an individual from the group was yelling to shoot him, then one of the individuals
shot Curtis. MOORE denied being the shooter. MOORE stated that “the shooter” used a 38 revolver. A

firearm and toolmark examiner confirmed that the projectile collected from Curtis Shelby was of the 38

family. MOORE stated that after the shooting, they all entered their vehicles and fled. MOORE claimed

that the involved individuals met up to discuss what their story would be to police.

MOORE stated that he was driving the white Ford Fusion. Officers had confirmed that the white

Ford Fusion was normally operated by MOORE’s girlfriend. MOORE stated that he was wearing yellow

that night and everyone else was wearing dark clothing. Multiple witnesses from the scene stated that the

person in yellow was the shooter.

All of the above events occurred in St. Joseph County, Indiana.

 I affirm under the penalty for perjury that the foregoing representations are true.

DETENTION CONSIDERATIONS

At the time of the offense, the Defendant had two open pending cases: 71D02-2210-F6-000929 and

71D02-2210-CM-001981. The Defendant is charged with murder and at the time of the offense, the
Defendant had two unrelated open pending cases: 71D02-2210-F6-000929 and 71D02-2210-CM-001981.

WHEREFORE, the State requests that the Court detain the Defendant until the Court conducts a bail

hearing in open court.

I affirm, under the pains and penalties for perjury, that the foregoing representations are true.

KRISTEN HARMON
DEPUTY PROSECUTING ATTORNEY