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BRYAN SCHRODER United States Attorney JACK S. SCHMIDT Assistant U.S. Attorney Federal Building & U.S. Courthouse 709 W. 9 th Street, Room 937 P.O. Box 21627 Juneau, Alaska 99802 Phone: (907 796-0400 Fax: (907 796-0409 Email: Jack.Schmidt@usdoj.gov Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA UNITED STATES OF AMERICA, vs. Plaintiff, CHRISTINA REYNA QUINTANA, a/k/a Lete ; ANDREA ROSE AVALOS, a/k/a Josie, PETER GEORGE KROVINA, a/k/a Lil Pete, PORTER WAYNE TREADWAY, HOLLY CHRISTINE CHAMBERS, AARON KEITH DIDRICKSON, and ERIC STEPHEN MORISKY, a/k/a Curly, Defendants. Case No. COUNT 1: DRUG CONSPIRACY Vio. of 21 U.S.C. 846 and 841(a(1, (b(1(a and (C COUNT 2: POSSESSION OF FIREARMS IN FURTHERANCE OF DRUG TRAFFICKING Vio. of 18 U.S.C. 924(c(1(A(ii and (iii COUNT 3 and 4: FELON IN POSSESSION OF A FIREARM Vio. of 18 U.S.C. 922(g(1 and 924(a(2 CRIMINAL FORFEITURE ALLEGATION NO. 1: 21 U.S.C. 853 and Rule 32.2(a Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 1 of 11

CRIMINAL FORFEITURE ALLEGATION NO. 2: 18 U.S.C. 924(d(1 and 28 U.S.C. 2461(c I N D I C T M E N T The Grand Jury charges that: COUNT 1 1. Beginning at some exact time unknown, but starting at least on or about May 2, 2017, and continuing until on or about April 3, 2018, both dates being approximate and inclusive, within the District of Alaska and elsewhere, the defendants, CHRISTINA REYNA QUINTANA, a/k/a Lete, ANDREA ROSE AVALOS, a/k/a Josie, PETER GEORGE KROVINA, a/k/a Lil Pete, PORTER WAYNE TREADWAY, HOLLY CHRISTINE CHAMBERS, AARON KEITH DIDRICKSON, and ERIC STEPHEN MORISKY, a/k/a Curly, did unlawfully, knowingly, and intentionally combine, conspire, confederate, and agree with each other and others known and unknown to the Grand Jury, to distribute and to possess with the intent to distribute, 50 grams or more of actual methamphetamine, and a mixture and substance containing a detectable amount of heroin. All of which is in violation of 21 U.S.C. 846 and 841(a(1, (b(1(a and (C. METHOD AND MEANS OF THE CONSPIRACY 2. It was part of the conspiracy for QUINTANA and AVALOS to obtain controlled substances from California and New Mexico for subsequent distribution in Sitka, Alaska. QUINTANA and AVALOS would intimidate other members in the Page 2 of 11 Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 2 of 11

conspiracy by telling other conspirators they were members of a larger drug trafficking gang. QUINTANA and AVALOS also organized a burglary and robbery of VICTIM A in order to collect a drug debt owed during the course of the conspiracy. KROVINA, TREADWAY, CHAMBERS, DIDRICKSON, MORISKY, and VICTIM A, were members of the drug conspiracy who assisted QUINTANA and AVALOS in the distribution of controlled substances, as well as the collection of drug debts from others. 3. QUINTANA, AVALOS, KROVINA, TREADWAY, CHAMBERS, DIDRICKSON, and MORISKY would possess firearms to facilitate their drug trafficking activities, as well as to extract retribution against members of the drug conspiracy who owed drug debts. The defendants perpetrated a violent act, involving a shooting, physical assaults, burglary and robbery in furtherance of their drug trafficking activities. OVERT ACTS 4. In furtherance of the conspiracy, and to effect the objects thereof, the defendants, together with persons known and unknown to the Grand Jury, performed and caused to be performed certain overt acts in the District of Alaska and elsewhere, including, but not limited to the following: OA1. On or about December 26, 2017, QUINTANA and AVALOS traveled to Sitka, Alaska for the purpose of distributing controlled substances. OA2. On or about March 3, 2018, MORISKY picked up $3,650 from VICTIM A at the direction of QUINTANA and AVALOS, which reduced VICTIM A s drug debt to $16,094. // Page 3 of 11 Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 3 of 11

OA3. On or about March 5, 2018, AVALOS texted KROVINA that I need to deal with Eric m. in reference to MORISKY s drug debt. OA4. On or about March 8, 2018, VICTIM A paid MORISKY $500 for a debt owed to QUINTANA and AVALOS, thereby reducing VICTIM A s drug debt to $15,594. OA5. Sometime during or after March 8, 2018, QUINTANA and AVALOS paid $900 towards VICTIM A s rent, as a result, VICTIM A now owed QUINTANA and AVALOS $16,464 and an additional 13 grams of a controlled substance. By March 18, 2018, VICTIM A owed QUINTANA and AVALOS $17,137 and 13 grams of a controlled substance. OA6. Sometime during March 2018, QUINTANA and AVALOS paid DIDRICKSON $30 for fuel and 2 grams of methamphetamine for transporting QUINTANA and AVALOS around Sitka, Alaska. OA7. On or about March 16, 2018, MORISKY purchased airline tickets for QUINTANA and AVALOS to travel from Juneau, Alaska to Sitka, Alaska. OA8. On or about March 16, 2018, QUINTANA and AVALOS arrived into Sitka, Alaska. They were picked up by DIDRICKSON and KROVINA, and who were supposed to assist to collect a drug debt from VICTIM A on that day; however, VICTIM A and B s children were at the residence. OA9. Sometime between the dates of March 16 and 17, 2018, DIDRICKSON sold QUINTANA a.22 caliber pistol with 10 rounds of.22 caliber ammunition intended to be used in furtherance of the drug conspiracy to collect the drug debt owed by VICTIM A. Page 4 of 11 Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 4 of 11

OA10. On or about March 17, 2018, QUINTANA, AVALOS, KROVINA, TREADWAY, and CHAMBERS met at TREADWAY s residence to plan the burglary and robbery of VICTIM A for the drug debt owed. OA11. On or about March 18, 2018, QUINTANA and AVALOS provided KROVINA a handwritten list for dealing with VICTIM A that was forwarded to DIDRICKSON. The list included the following items: zip ties, 5 pairs of black gloves, black sweats and tees. OA12. On or about March 18, DIDRICKSON dropped off QUINTANA and AVALOS at TREADWAY s residence. At the residence, QUINTANA and AVALOS met KROVINA, TREADWAY, and CHAMBERS, where they discussed their plans for assaulting VICTIM A. The conspirators were in possession of a.22 caliber pistol that was sold by DIDRICKSON. Later that afternoon QUINTANA, AVALOS, and TREADWAY left TREADWAY s residence in CHAMBER s vehicle headed towards Sawmill Creek Road where QUINTANA test fired the pistol, recovered the shell casing, and placed it back into CHAMBERS vehicle. OA13. On or about March 18, 2018, CHAMBERS drove QUINTANA, AVALOS, and TREADWAY back to TREADWAY s residence, picked up KROVINA and drove to VICTIM A and B s residence. Upon arriving at the residence, CHAMBERS parked the vehicle around the corner away from VICTIM A and B s residence. OA14. On or about March 18, 2018, CHAMBERS texted VICTIM A, who was at the grocery store, and asked if they want to hang out together. VICTIM A asked for a ride in 15 minutes. Page 5 of 11 Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 5 of 11

OA15. On or about March 18, 2018, CHAMBERS and AVALOS walked up to the residence and contacted VICTIM A and B s children at the residence. QUINTANA, KROVINA and TREADWAY went to the back of the residence. CHAMBERS offered the children to go out for ice cream and left the scene with them, in order to facilitate the assault. OA16. On or about March 18, 2018, QUINTANA, AVALOS, KROVINA, and TREADWAY ransacked and searched VICTIM A and B s residence for money and controlled substances. During their search, a 10mm Glock and a 12 gauge shotgun were found and possessed by QUINTANA and KROVINA, and used in furtherance of the drug conspiracy. OA17. On or about March 18, 2018, VICTIM A and B took a cab to their residence after CHAMBERS did not arrive to pick them up. Upon arriving at their residence, VICTIM B entered the residence while VICTIM A paid for the cab. TREADWAY attacked VICTIM B with a claw hammer until VICTIM B was unconscious. KROVINA went outside with the Mossberg 12 gauge shotgun and ordered VICTIM A into the residence at gunpoint. OA18. On or about March 18, 2018, a conspirator asks VICTIM B Where s the money? while striking VICTIM B with the hammer. OA19. On or about March 18, 2018, QUINTANA brandished a 10mm Glock, and demanded payment from VICTIM A for the drug debt, and subsequently shot VICTIM A in both legs. The group left the residence of VICTIM A and B. KROVINA carried a suitcase containing personal property of the victims. Page 6 of 11 Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 6 of 11

OA20. On or about March 18, 2018, QUINTANA, AVALOS, KORVINA, and TREADWAY left the residence and called DIDRICKSON to pick them up at the hill behind the residence. DIDRICKSON drove to the scene and picked up QUINTANA, AVALOS, and TREADWAY in Sollar s Trailer Park and took them to a local trailhead in order to elude police. OA21. On or about March 18, 2018, QUINTANA and AVALOS contacted MORISKY, who lived aboard the unpowered M/V RUBATO, and hid QUINTANA and AVALOS on the vessel. MORISKY texted various individuals asking them to keep a look out for police and to advise him if police came around the harbor. OA22. On or about March 18, 2018, QUINTANA possessed approximately 50 grams of methamphetamine. OA23. On or about March 19, 2018, MORISKY attempted to secure transportation of QUINTANA and AVALOS from Sitka, Alaska to Juneau, Alaska. OA24. On or about March 19, 2018, QUINTANA and AVALOS possessed approximately 36 grams of methamphetamine. OA25. On or about April 3, 2018, DIDRICKSON possessed a 10mm Glock pistol, which had been stolen from VICTIM A. COUNT 2 On or about March 18, 2018, within the District of Alaska, the defendants, CHRISTINA REYNA QUINTANA, a/k/a Lete, ANDREA ROSE AVALOS, a/k/a Josie, PETER GEORGE KROVINA, a/k/a Lil Pete, PORTER WAYNE TREADWAY, HOLLY CHRISTINE CHAMBERS, AARON KEITH DIDRICKSON, Page 7 of 11 Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 7 of 11

and ERIC STEPHEN MORISKY, a/k/a Curly, did knowingly and intentionally possess, brandish, and discharge firearms, in furtherance of a drug trafficking crime, to wit, drug conspiracy, and did use and carry a firearms during and in relation to said offense. All of which is in violation of 18 U.S.C. 924(c(1(A(ii and (iii. COUNT 3 On or about March 18, 2018, within the District of Alaska, the defendant, CHRISTINA QUINTANA, a/k/a Lete, having been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly possess, in and affecting interstate and foreign commerce, a firearm, to wit: 1. Glock 20, 10mm caliber pistol; and 2. Mossberg, 12 gauge shotgun. Convictions Conviction Date Offense Court Case No. 11/10/2015 Vehicle Theft in the Santa Ana County, 15WF0279 First Degree California 09/12/2008 Felon in Possession of a Firearm Westminster County, California 07WF2806 07/12/2006 Felon in Possession of a Firearm Westminster County, California All of which is in violation of 18 U.S.C. 922(g(1 and 924(a(2. 06WF1274 Page 8 of 11 Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 8 of 11

COUNT 4 On or about May 18, 2018, within the District of Alaska, the defendant, PORTER WAYNE TREADWAY, having been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly possess, in and affecting interstate and foreign commerce, a firearm, to wit, 1. Glock 20, 10mm caliber pistol; and 2. Mossberg, 12 gauge shotgun. Convictions Conviction Date Offense Court Case No. 02/27/2013 Theft in the Second Degree and Forgery in the Second Degree State of Alaska First Judicial District at Sitka 1SI-12-233CR. All of which is in violation of 18 U.S.C. 922(g(1 and 924(a(2. CRIMINAL FORFEITURE ALLEGATION NO. 1 DRUG PROCEEDS AND FACILITATING PROPERTY Upon conviction of Count 1 of this Indictment, the defendants, CHRISTINA REYNA QUINTANA, a/k/a Lete, ANDREA ROSE AVALOS, a/k/a Josie, PETER GEORGE KROVINA, a/k/a Lil Pete, PORTER WAYNE TREADWAY, HOLLY CHRISTINE CHAMBERS, AARON KEITH DIDRICKSON, and ERIC STEPHEN MORISKY, a/k/a Curly, shall forfeit to the United States pursuant to 21 U.S.C. 853(a(1 and (a(2 any property constituting, or derived from, any proceeds obtained, directly or indirectly, as the result of such offense and any property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, the offense. The property to be forfeited includes, but is not limited to, the following: Page 9 of 11 Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 9 of 11

Procedure. 1. Glock 20, 10mm caliber pistol, S/N BFUM744; 2. Smith and Wesson.22 caliber pistol, no serial number; and 3. Mossberg, 12 gauge shotgun, S/N T690098. All pursuant to 21 U.S.C. 853 and Rule 32.2(a, Federal Rules of Criminal CRIMINAL FORFEITURE ALLEGATION NO. 2 FIREARMS Upon conviction of Count 2, 3, or 4 of this Indictment, the defendants, CHRISTINA REYNA QUINTANA, a/k/a Lete, ANDREA ROSE AVALOS, a/k/a Josie, PETER GEORGE KROVINA, a/k/a Lil Pete, PORTER WAYNE TREADWAY, HOLLY CHRISTINE CHAMBERS, AARON KEITH DIDRICKSON, and ERIC STEPHEN MORISKY, a/k/a Curly, shall forfeit to the United States pursuant to 18 U.S.C. 924(d(1, and 28 U.S.C. 2461(c, any firearms and ammunition involved or used in the commission of the offense, including but not limited to: 1. Glock 20, 10mm caliber pistol, S/N BFUM744; and 2. Mossberg, 12 gauge shotgun, S/N T690098. All pursuant to 18 U.S.C. 924(d(1 and 28 U.S.C. 2461(c. Page 10 of 11 Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 10 of 11

Substitute Property If any of the property described above, as a result of any act or omission of the defendants cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction of the court; has been substantially diminished in value; or has been commingled with other property which cannot be divided without difficulty, the United States shall be entitled to forfeiture of substitute property pursuant to 21 U.S.C. 853(p. All pursuant to 21 U.S.C. 853, and Rule 32.2(a, Federal Rules of Criminal Procedure. A TRUE BILL. s/ Grand Jury Foreperson GRAND JURY FOREPERSON s/ Jack S. Schmidt JACK S. SCHMIDT United States of America Assistant U.S. Attorney s/ Bryan Schroder BRYAN SCHRODER United States of America United States Attorney DATE: 4-17-18 Page 11 of 11 Case 1:18-cr-00007-TMB-LCL Document 2 Filed 04/19/18 Page 11 of 11