UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. ________ _ 

8 U.S.C. § 1324(a)(2)(B)(ii) 

18 U.S.C. § 982(a)(6) 

UNITED STATES OF AMERICA 

v. 

MAHANDRASOOKRAM, FILED sv_s ____ o.c. 

Defendant. 

I SEP 1 3 2022 -----------------

INDICTMENT 

The Grand Jury charges that: 

COUNTS 1-6 

On or about August 31 , 2022, within the Special Maritime and Territorial Jurisdiction of 

the United States, and elsewhere, with Palm Beach County, in the Southern District of Florida, 

being the district to which the offender was first brought, the defendant, 

MAHANDRA SOOKRAM, 

did knowingly bring to the United States aliens by any manner whatsoever, as set forth in Counts 

1 through 6 below, knowing and in reckless disregard of the fact that such aliens had not received 

prior official authorization to come to, enter, and reside in the United States, and regardless of 

any official action which may later be taken with respect to such aliens, for the purpose of 

commercial advantage and private financial gain: 

Count Alien 

--

1 D.B. 

2 C.D. 

22-cr-80146-Cannon/Reinhart

Case 9:22-cr-80146-AMC Document 9 Entered on FLSD Docket 09/13/2022 Page 1 of 5
3 S.G. 

4 V.L. 

5 R.R. 

6 D.S. 

All in violation of Title 8, United States Code, Section 1324(a)(2)(B)(ii) and Title 18, 

United States Code, Section 2. 

FORFEITURE ALLEGATIONS 

1. The allegations of this Indictment are hereby re-alleged and by this reference fully 

incorporated herein for the purpose of alleging forfeiture to the United States of America of 

certain property in which the defendant, MAHANDRA SOOKRAM, has an interest. 

2. Upon conviction of a violation of Title 8, United States Code, Section 1324, as 

alleged in this Indictment, the defendant shall forfeit to the United States, pursuant to Title 18, 

United States Code, Section 982(a)(6): 

a. any conveyance, including any vessel, vehicle, or aircraft, used in the 

commission of such offense; 

b. any property, real or personal, that constitutes, or is derived from, or is 

traceable to any proceeds obtained, directly or indirectly, from the commission of 

such offense; and 

c. any property, real or personal, that was used to facilitate, or intended to be 

used to facilitate, the commission of such offense. 

All pursuant to Title 18, United States Code, Section 982(a)(6) and the procedures set 

2 

Case 9:22-cr-80146-AMC Document 9 Entered on FLSD Docket 09/13/2022 Page 2 of 5
forth in Title 21, United States Code, Section 853 , as incorporated by Title 18, United States 

Code, Section 982(b )( 1 ). 

A TRUE BILL 

RNEY 

L T ... 'U..J.......... GATZ 

ASS STANT UNITED STATES ATTORNEY 

3 

Case 9:22-cr-80146-AMC Document 9 Entered on FLSD Docket 09/13/2022 Page 3 of 5
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

UNITED STATES OF AMERICA 

v. CASE NO.: 

MAHANDRA SOOKRAM, 

-------------/ CERTIFICATE OF TRIAL ATTORNEY* 

Superseding Case Information: 

Court Division (select one) 

□ Miami □ Key West FTP 

New Defendant(s) (Yes or No) 

Number of New Defendants 

□ FTL ~ WPB Total number of New Counts 

I do hereby certify that: 

l. I have carefu ll y considered the allegations of the indictment, the number of defendants, the number of probab le 

witnesses and the legal complexities of the lndictment/lnformation attached hereto. 

2. I am aware that the information supplied on this statement will be reli ed upon by the Judges of this Court in setting 

their calendars and sched uling criminal trials under the mandate of the Speedy Trial Act, Title 28 U.S.C. §3 16 I. 

3. Interpreter: (Yes or No) NO 

List language and/or dialect: 

4. This case will takeFIVE days for the parties to try. 

5. Please check appropriate category and type of offense listed below: 

(Check only one) 

I ~ 0 to 5 days 

II D 6 to 10 days 

III D 11 to 20 days 

IV D 21 to 60 days 

V D 61 days and over 

(Check on ly one) 

□ Petty 

D Minor 

D Misdemeanor 

00 Felony 

6. Has this case been previously filed in this District Court? (Yes or o) NO 

ff yes, Judge Case No. 

7. Has a complaint been filed in this matter? (Yes or No) YES 

If yes, Magistrate Case No. 22-MJ-8395 

8. Does this case relate to a previously filed matter in this District Court? (Yes or No) NO 

Jf yes, Judge Case No. 

9. Defendant(s) in federa l custody as of August 31, 2022 

10. Defendant(s) in state custody as of 

11. Rule 20 from the District of 

12. Is this a potential death penalty case? (Yes or No) NO 

13. Does this case originate from a matter pending in the Northern Region of the U.S. Attorney 's Office 

prior to August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No) NO 

14. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office 

prior to October 3, 20 I 9 (Mag. Judge Jared Strauss? (Yes or No) NO 

By: L Cl-V ev T v~ G at"lf 

Lara Treinis Gatz 

Assistant United States Attorney 

Court ID No. A5502857 

22-cr-80146-Cannon/Reinhart

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UNITED ST ATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: MAHANDRA SOOKRAM 

Case No: ______________________________ _ 

Bringing Aliens into the United States Title 8, United States Code, § 1324{a){2){B)(ii) 

Counts One and Two 

* Max. Term of Imprisonment: 10 Years 

* Mandatory Min. Term of Imprisonment (if applicable): 3 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 

Bringing Aliens into the United States Title 8, United States Code,§ 1324(a)(2)(B)(ii) 

Counts Three through Six 

* Max. Term of Imprisonment: 15 Years 

* Mandatory Min. Term of Imprisonment (if applicable): 5 years 

*Max.Supervised Release: 3 years 

* Max. Fine: $250,000 

*Refers only to possible term of incarceration, supervised release and fines. It does not include 

restitution, special assessments, parole terms, or forfeitures that may be applicable. 

22-cr-80146-Cannon/Reinhart

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