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Case Document 12 Filed 06/07/16 Page 1 of 4 PageID 30

UNITED STATES OF AMERICA

V.

MARTAVIOUS DETREL BANKS KEYS
AKA ?Cheese? AKA ?Matt?

 

INDICTMENT 3 

The Grand Jury charges:

Count One
Sex Traf?cking of Children

FOR THE NORTHERN DISTRICT OF 
DALLAS DIVISION

NO.

IN THE UNITED STATES DISTRICT COURT

 

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(Violation of 18 U.S.C. 1591(a) and 

From on or about March 15, 2015 through on or about April 18, 2015, the exact

dates being unknown, in the Dallas Division of the Northern District of Texas and

elsewhere, the defendant, Martavious Detrel Banks Keys a.k.a. ?Cheese,? a.k.a

?Matt,? knowingly recruited, enticed, harbored, transported, provided, obtained or

maintained by any means, in and affecting interstate commerce, Jane Doe, who had not

attained the age of 18 years, knowing or in reckless disregard of the fact that Jane Doe

had not attained the age of 18 years and that Jane Doe would be caused to engage in a

commercial sex act.

In violation of 18 U.S.C. 1591(a) and 

Indictment Page 1

Case Document 12 Filed 06/07/16 Page 2 of 4 PageID 31

Forfeiture Notice
(18 U.S.C. 1594(d) and 28 U.S.C. ?2461(c))

Upon conviction for the offense alleged in Count One of this Indictment and
pursuant to 18 U.S.C. 1594(d), the defendant, Martavious Detrel Banks Keys a.k.a.
?Cheese,? a.k.a ?Matt,? shall forfeit to the United States any property, real or personal,
that was used or intended to be used to commit or to facilitate the commission of such

Violation and any property, real or personal, constituting or derived from, any proceeds

that such person obtained, directly or indirectly, as a result of such Violation.

Indictment Page 2

 

Case 3:16-cr-00244-N Document 12 Filed 06/07/16 Page 3 of 4 PageID 32

A TRUE BILL:



JOHN R. PARKER
UNITED STATES ATTORNEY

CARA FOOS PIERCE
Assistant United States Attorney
Texas State Bar No. 24036579
1100 Commerce, Third Floor
Dallas, TX 75242

Telephone: 214.659.8600
Facsimile: 214.659.8803
cara.pierce@usdoj.gov

Indictment Page 3

Case Document 12 Filed 06/07/16 Page 4 of 4 PageID 33

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

 

THE UNITED STATES OF AMERICA
V.

7 MARTAVIOUS DETREL BANKS KEYS
AKA ?Cheese? AKA ?Matt?

 

INDICTMENT

18 U.S.C. 1591(a) and 
Sex Traf?cking of Children

18 U.S.C. 1594(d) and 28 U.S.C. ?2461(c)
Forfeiture Notice

 

 

 

1 Count
A true bill rendered
-- 
DALLAS 

 

Filed in open court this 7th day of June, 2016.

 

 

No Warrant Needed

 

     
   
    

   
  
 

   

UNITED ATES GISTRATE JUDE
Magistrate Court Number: 3 -16-MJ-827-BH