UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. 22-MJ-(500)

UNITED STATES OF AMERICA 

vs. 

0$+$1'5$622.5$0

'HIHQGDQW

CRIMINAL COVER SHEET 

1. 1. Did this matter originate from a matter pending in the United States 

Attorney’s Office prior to August 9, 2013 (Mag. Judge Alicia Valle)? 

Yes X No 

2. Did this matter originate from a matter pending in the Northern Region of the

United States Attorney’s Office prior to August 8, 2014 (Mag. Judge Shaniek

Maynard)? Yes X No

Respectfully submitted, 

JUAN ANTONIO GONZALEZ 

UNITED STATES ATTORNEY 

By: Lara Treinis Gatz

Lara Treinis Gatz 

Assistant United States Attorney 

Southern District of Florida 

Court ID No. A5502857 

500 S. Australian Avenue – 4th Floor West 

:HVWPalm Beach, Florida 401 

lara.gatz@usdoj.gov

(561) 209-1069

8395

SP Sep 6, 2022 West Palm Beach

Case 9:22-cr-80146-AMC Document 1 Entered on FLSD Docket 09/06/2022 Page 1 of 9
AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

__________ District of __________

United States of America )

)

)

)

)

)

)

v.

Case No.

Defendant(s)

CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the date(s) of in the county of in the

District of , the defendant(s) violated:

Code Section Offense Description

This criminal complaint is based on these facts: 

u Continued on the attached sheet.

Complainant’s signature

Printed name and title

Sworn to before me and signed in my presence.

Date:

Judge’s signature

City and state:

Printed name and title

 Southern District of Florida

MAHANDRA SOOKRAM, 22-MJ- (RMM)

August 31, 2022 Palm Beach

Southern Florida

8 USC 1324(a)(1)(A)(i) Bringing aliens into to the United States

SEE ATTACHED AFFIDAVIT

✔

Special Agent Joshua Woody, HSI

09/05/2022

West Palm Beach,Florida HONORABLE RYON M. McCABE, USMJ

JOSHUA J 

WOODBURY

Digitally signed by JOSHUA J 

WOODBURY 

Date: 2022.09.05 11:16:13 -04'00'

8395

SP Sep 6, 2022 West Palm Beach

Case 9:22-cr-80146-AMC Document 1 Entered on FLSD Docket 09/06/2022 Page 2 of 9
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 

 I, Joshua Woodbury, first being duly sworn, does hereby depose and state as follows: 

 1. I am a Special Agent with the United States Department of Homeland Security, 

Homeland Security Investigations (“HSI”) and have been so employed since June 2008. Prior 

to my employment with HSI, I worked as a United States Customs Inspector for six and a half 

years. As part of my duties and responsibilities as an HSI Special Agent, I have become 

familiar with the criminal offenses set forth in Title 8 of the United States Code, the 

Immigration and Nationality Act. Moreover, I have conducted investigations involving human 

smuggling and their related criminal activity and have become familiar with the methods and 

schemes employed by individuals who smuggle persons into the United States. 

 2. The facts set forth in this affidavit are based on my personal knowledge, 

information obtained from others, including other law enforcement officers, my review of 

documents, pictures, GPS data, text messages and computer records. Because this affidavit is 

being submitted for the limited purpose of establishing probable cause to support a criminal 

Complaint, I have not included each and every fact known to me and law enforcement, rather, 

I have included only those facts necessary to establish probable cause to believe that, on or 

about August 31, 2022, defendant MAHANDRA SOOKRAM did knowingly and willfully 

bring and attempt to bring aliens to the United States in violation of Title 8, United States 

Code, Section 1324(a)(1)(A)(i). 

 PROBABLE CAUSE 

 3. On August 31, 2022, at approximately 9:30 p.m. Customs and Border Protection 

(CBP) Air and Marine became aware of a vessel approximately 20 nautical miles east of the 

Lake Worth Inlet, and then at approximately 10:15 p.m. stopped that vessel. CBP officers 

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observed the defendant MAHANDRA SOOKRAM (“SOOKRAM”) piloting the vessel, which 

was carrying six passengers. Upon questioning, defendant SOOKRAM advised CBP officers 

that they were returning to West Palm Beach from a day of fishing. Defendant SOOKRAM 

further advised that he was a U.S. Citizen, while the other six individuals reported to CBP 

officers that they were Guyanese nationals. 

 4. Thereafter, during a search of the vessel, CBP officers discovered airplane 

boarding passes dated August 31, 2022 in the names of the six Guyanese nationals aboard the 

vessel which documented travel earlier that day from Georgetown, Guyana to Port of Spain 

Trinidad and Tobago, with a final destination of Freeport, Bahamas. Further, a review of the 

GPS device located on the vessel recorded the vessel departing a Marina located in Palm Beach 

County, Florida1

 at approximately 6:40 a.m. that day, and arriving at the Old Bahama Bay 

resort at West End, Bahamas at approximately 9:40 a.m. Then, at 8:05 p.m., the vessel 

departed the West End, Bahamas and headed due west towards the United States, returning to 

Lake Worth Inlet. 

 5. Then, at approximately 8:30 p.m. on September 2, 2022, defendant SOOKRAM 

was brought to the Coast Guard Station in Lake Worth to be processed and interviewed by HSI 

Agents. After being advised of his Miranda rights, which he waived, agreeing to answer 

questions, defendant SOOKRAM said, in sum and in part, that he left Lake Worth in the early 

morning hours to go to Freeport, Bahamas because he has not seen his daughter in over twenty 

years. Defendant SOOKRAM said he wanted to bring his daughter and her son to the coast of 

the United States to see the lights and that he thought the coast of the United States was 3 miles 

1

 Defendant SOOKRAM’s vehicle with an attached boat trailer was later located in the 

parking lot of the Marina. 

Case 9:22-cr-80146-AMC Document 1 Entered on FLSD Docket 09/06/2022 Page 4 of 9
offshore. Defendant SOOKRAM further told agents that the other people on the vessel were 

his daughter’s ex mother-in-law, his daughter’s boyfriend, and friends his daughter’s 

boyfriend. Defendant SOOKRAM stated that he intended to return everyone back to the 

Bahamas. Then, when agents asked defendant SOOKRAM to clarify where in the Bahamas 

he went that day, defendant SOOKRAM admitted he actually went to West End and not 

Freeport. Finally, when confronted with several inconsistencies in his story, defendant 

SOOKRAM declined to answer further questions. 

 6. As part of the investigation, law enforcement officers conducted database 

checks concerning the six Guyanese nationals located on the vessel and discovered that two of 

the people on board were previously denied visas to enter the United States as it was 

determined their intentions were not to come to the United States as visitors, but as intended 

immigrants. 

 7. Further, a review of defendant SOOKRAM’s cellphone reveals text message 

communications between himself, and someone listed as “David NY.” In July 2022 text 

message exchanges between the two, defendant SOOKRAM advised that he had an “opening 

next month” for a friend of David’s, and, during further communications, the two discuss 

“payment.” Then, in an August 29, 2022 text exchange, David NY sent defendant SOOKRAM 

a picture of a biographic page of a Guyanese passport for an individual whose identity is known 

to your affiant, hereafter referred to as RR. RR was one of the aliens found on the vessel on 

August 31, 2022, and is one of the two individuals previously denied a visa to enter the United 

States. 

 8. Also located on defendant SOOKRAM’s cellphone were text message 

exchanges directly between defendant SOOKRAM and RR. In particular, on July 21, 2022, 

Case 9:22-cr-80146-AMC Document 1 Entered on FLSD Docket 09/06/2022 Page 5 of 9
defendant SOOKRAM sent RR a text message stating, “David gave me your number, I’m the 

guy who will be bringing you,” to which RR responded, “ok cool let me know what I have to 

do.” Then, on August 4, 2022, RR sent defendant SOOKRAM a text message stating, “I didn’t 

get anyone as of yet who wants to come, I asked two persons, but they are scared to take the 

risk,” to which defendant SOOKRAM replied, “everything is good we are full I will give you 

a call at 8.” Then, on August 7, 2022, defendant SOOKRAM sent RR photographs of the 

biographical pages of passports of four individuals (who were also found on the vessel on 

August 31, 2022) and stated, “these are the people you will be traveling with.” Then, on 

August 31, 2022, at approximately 3:48 p.m. defendant SOOKRAM sent RR pictures of the 

vessel, and, at approximately 6:57 p.m. RR responded, “we are on our way,” to which 

defendant SOOKRAM replied “go to the West End clinic right by the boat ramp tell the driver 

that.”

9. Finally, multiple text message exchanges were located on defendant

SOOKRAM’s cellphone in which, between July and August 2022, various individuals discuss 

paying defendant SOOKRAM to transport them to the United States (including some of the 

individuals found on the vessel on August 31, 2022). It appears from the text messages 

exchanges that defendant SOOKRAM charged $10,000 per person for his smuggling services. 

10. Based on the foregoing, I submit that probable cause exists to believe that, on

or about August 31, 2022, defendant MAHANDRA SOOKRAM brought and attempted to 

Case 9:22-cr-80146-AMC Document 1 Entered on FLSD Docket 09/06/2022 Page 6 of 9
bring aliens to the United States in violation of Title 8, United States Code, Section 

1324(a)(1)(A)(i). 

 

 _______________________________ 

 JOSHUA WOODBURY 

 Special Agent 

 Homeland Security Investigations 

Sworn and Attested to me by Applicant by Telephone (Facetime) pursuant to Fed. R. Crim. P. 

4(d) and 4.1 this 5th day of September 2022. 

_____________________________________ 

THE HONORABLE RYON M. McCABE 

UNITED STATES MAGISTRATE JUDGE 

 

JOSHUA J 

WOODBURY

Digitally signed by JOSHUA J 

WOODBURY 

Date: 2022.09.05 11:15:21 

-04'00'

Case 9:22-cr-80146-AMC Document 1 Entered on FLSD Docket 09/06/2022 Page 7 of 9
*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.

UNITED STATES 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)(1)(A)(i) 

* Max. Term of Imprisonment: 10 Years

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

* Max. Supervised Release: 3 years

* Max. Fine: $250,000

22-mj-8395-RMM

Case 9:22-cr-80146-AMC Document 1 Entered on FLSD Docket 09/06/2022 Page 8 of 9
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case Number: 22-MJ-500

BOND RECOMMENDATION 

DEFENDANT6: 0$+$1'5$622.5$0

35(75,$/ '(7(17,21BBBBBBBBBBBBBBBBBBBBBBBBBBBB

(Personal Surety)(Corporate Surety) (Cash) (Pretrial 

Detention) 

By: Lara Treinis Gatz 

 LARA TREINIS GATZ 

 ASSISTANT U.S. ATTORNEY 

Last Known Address:6RORPDQ5RDG-DFNVRQYLOOH)ORULGD

What Facility: Palm Beach County Jail 3228 Gun Club Rd, West Palm Beach, FL 33406 

Agent(s): 63(&,$/$*(17-26+8$:22'%85<+6, 

)%,(SECRET SERVICE)(DEA)(IRS)(ICE)(27+(5) 

8395

Case 9:22-cr-80146-AMC Document 1 Entered on FLSD Docket 09/06/2022 Page 9 of 9