AO 91 (Rev. 02/09) Criminal Complaint
for the
Western District of Texas
United States of America
Keith Allen FELUX
I, the complainant in this case, state that the following is true to the best
On or about the date of
11/14/2014 in the county of
, the defendant violated
an offense described as follows:
of my knowledge and belief.
U. S. C.
in the
District of
2422 (b)
did use any facility and foreign commerce, to wit: a cellular telephone and by Facebook Messenger, to knowingly
attempt to persuade, induce and entice an individual who had not attained the age of 18 years to engage in sexual
This criminal complaint is based on these facts:
See attachment titled AFFIDAVIT"
Continued on the attached sheet.
Comp inant signature
Yon, Special Agent
Printed name and title
Sworn to before me and signed in my presence.
Judge 's signature
City and state:
Midland, Texas
David Counts
U.S. Magistrate Judge
Printed name and title
I, Daniel Yon, being duly sworn do hereby depose and state as follows:
I am a Special Agent of the Department of Homeland Security (DHS). I am currently
assigned to the Homeland Security Investigations (HSI) office in Midland, Texas.
I am familiar with the information contained in this affidavit based both upon the
investigation I have conducted and based on my conversations with other law enforcement
officers involved in this investigation.
The facts in this affidavit come from my personal observations, my training and
experience and information obtained from other agents and witnesses. This affidavit is intended
to show merely that there is sufficient probable cause for the criminal charges being described
below in this matter.
Based on my training and experience and the facts as set forth in this affidavit, there is
probable cause to believe that violations of 18 U.S.C. § 2422(b) (using internet and/or phone text
messages in an attempt to entice a minor to engage in sexual activity) have been committed by
Keith FELUX.
On November 15, 2014, the defendant, later identified as Keith FELUX, sent an email to
a person whom he believed to be a female child 14 years of age, and hereafter referred to as Jane
Doe 1. During the email conversations with Jane Doe 1, FELUX asked her "... how old are you"
Jane Doe 1 responded to FELUX by saying, "almost 15 but i look alot older how old r u". After
knowing Jane Doe 1 was 14 years of age, FELUX sends Jane Doe 1 his telephone number and
asks her to "text me".
The conversation continues through text messages and Jane Doe 1 asks FELUX, "did u
get my pic", to which FELUX responds "Tm still waiting for the pic I think you're a cop".
Further along in the chat conversation Jane Doe 1 asks FELUX, "what r u wanting to do u never
told me my surprise", to which FELUX responds, "I'm going to fuck you if you let me". FELUX
states further along in the conversation "Are you a virgin", and asks Jane Doe 1 to "Send me a
dirty pic so I know your really down", "I think u are beautiful". Approximately one minute later
FELUX asks again for Jane Doe 1 to "Send me a dirty pic". Jane Doe 1 responds "do you want
to take some pics of me" to which FELUX, responds "I would love to but I want to see what I'm
going to be fucking".
Jane Doe 1 asked FELUX to meet her at a designated location in Midland, Texas and
FELUX agreed. FELUX signaled Jane Doe 1 to show that he was there to pick her up. FELUX
was identified by this action and taken into custody by the Midland County Sherriff' s Office.
FELUX was transported to the Midland Texas Department of Public Safety (DPS) office
in Midland Texas. Prior to being interviewed, FELUX was advised of his Constitutional rights to
remain silent and he agreed to speak with law enforcement agents about his arrest. During the
interview, FELUX admitted that he knew Jane Doe 1 was fourteen years of age and stated that he
"would have had sex with her, if she had let him".
Based on the foregoing your affiant submits that probable cause exists to believe that
Keven ACOSTA-Martinez is in violation of Title 18 United States Code, Section 2422(b)
Coercion and Enticement of a Minor.
The punishment range for violation of Title 18 United States Code, Section 2422(b)
Coercion and Enticement of a Minor, is a 10-year mandatory minimum term of imprisonment,
up to life; a 5-year mandatory minimum term of supervised release, a fine up to $250,000 and
a $100 special assessment fee.
R. Yon
Homeland Security Investigations
Sworn to and su cribed before me this
David Counts
United States Magistrate Judge
day of November, 2014.