UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 22-CR-80146-AMC 

UNITED STATES OF AMERICA 

vs. 

MAHANDRA SOOKRAM, 

Defendant. 

I ----------------

PLEA AGREEMENT 

The United States Attorney's Office for the Southern District of Florida ("this Office") 

and MAHANDRA SOOKRAM (hereinafter referred to as the "defendant") enter into the 

following agreement: 

1. The defendant agrees to plead guilty to Count One of the Indictment which count 

charges the defendant with Bringing in and Harboring Certain Aliens for Profit in violation of 

Title 8, United States Code, Section 1342(a)(2)(B)(ii). 

2. This Office agrees to seek dismissal of Counts Two through Six of the Indictment, 

as to this defendant, after sentencing. 

3. The defendant is aware that the sentence will be imposed by the Court after 

considering the advisory Federal Sentencing Guidelines and Policy Statements (hereinafter 

"Sentencing Guidelines"). The defendant acknowledges and understands that the Court will 

compute an advisory sentence under the Sentencing Guidelines and that the applicable 

guidelines will be determined by the Court relying in part on the results of a pre-sentence 

investigation by the Court's probation office, which investigation will commence after the 

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guilty plea has been entered. The defendant is also aware that, under certain circumstances, 

the Court may depart from the advisory sentencing guideline range that it has computed and 

may raise or lower that advisory sentence under the Sentencing Guidelines. The defendant is 

further aware and understands that the Court is required to consider the advisory guideline 

range determined under the Sentencing Guidelines but is not bound to impose a sentence 

within that advisory range; the Court is permitted to tailor the ultimate sentence in light of 

other statutory concerns, and such sentence may be either more severe or less severe than the 

Sentencing Guidelines' advisory range. Knowing these facts, the defendant understands and 

acknowledges that the Court has the authority to impose any sentence within and up to the 

statutory maximum authorized by law for the offense identified in paragraph 1 and that the 

defendant may not withdraw the plea solely as a result of the sentence imposed. 

4. The defendant also understands and acknowledges that the Court must impose a 

minimum term of imprisonment of three years and may impose a statutory maximum term of 

imprisonment of up to ten years, followed by a term of supervised release of up to 

three years. In addition to a term of imprisonment and supervised release, the Court may 

impose a fine of up to $250,000 and may order forfeiture and restitution. 

5. The defendant further understands and acknowledges that, in addition to any 

sentence imposed under paragraph 4 of this agreement, a special assessment in the amount of 

$100 will be imposed on the defendant. The defendant agrees that any special assessment 

imposed shall be paid at the time of sentencing. If a defendant is financially unable to pay the 

special assessment, the defendant agrees to present evidence to this Office and the Court at the 

time of sentencing as to the reasons for the defendant's failure to pay. 

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6. This Office reserves the right to inform the Court and the probation office of all 

facts pertinent to the sentencing process, including all relevant information concerning the 

offenses committed, whether charged or not, as well as concerning the defendant and the 

defendant's background. Subject only to the express terms of any agreed-upon sentencing 

recommendations contained in this agreement, this Office further reserves the right to make 

any recommendation as to the quality and quantity of punishment. 

7. This Office agrees that it will recommend at sentencing that the Court reduce by 

two levels the sentencing guideline level applicable to the defendant's offense, pursuant to 

Section 3El. l(a) of the Sentencing Guidelines, based upon the defendant's recognition and 

affirmative and timely acceptance of personal responsibility. If at the time of sentencing the 

defendant's offense level is determined to be 16 or greater, this Office will file a motion 

requesting an additional one level decrease pursuant to Section 3E 1.1 (b) of the Sentencing 

Guidelines, stating that the defendant has assisted authorities in the investigation or 

prosecution of the defendant's own misconduct by timely notifying authorities of the 

defendant's intention to enter a plea of guilty, thereby permitting the government to avoid 

preparing for trial and permitting the government and the Court to allocate their resources 

efficiently. This Office further agrees to recommend that the defendant be sentenced to the 

statutory minimum sentence of36 months. This Office, however, will not be required to make 

this motion and this recommendation if the defendant: ( 1) fails or refuses to make a full, 

accurate and complete disclosure to the probation office of the circumstances surrounding the 

relevant offense conduct; (2) is found to have misrepresented facts to the government prior to 

entering into this plea agreement; or (3) commits any misconduct after entering into this plea 

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agreement, including but not limited to committing a state or federal offense, violating any 

term of release, or making false statements or misrepresentations to any governmental entity 

or official. 

8. The defendant is aware that the sentence has not yet been determined by the Court. 

The defendant is also aware that any estimate of the probable sentencing range or sentence that 

the defendant may receive, whether that estimate comes from the defendant's attorney, this 

Office, or the probation office, is a prediction, not a promise, and is not binding on this Office, 

the probation office or the Court. The defendant understands further that any 

recommendation that this Office makes to the Court as to sentencing, whether pursuant to this 

agreement or otherwise, is not binding on the Court and the Court may disregard the 

recommendation in its entirety. The defendant understands and acknowledges, as previously 

acknowledged in paragraph 3 above, that the defendant may not withdraw his plea based upon 

the Court's decision not to accept a sentencing recommendation made by the defendant, this 

Office, or a recommendation made jointly by the defendant and this Office. 

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9. This is the entire agreement and understanding between this Office and the 

defendant. There are no other agreements, promises, representations, or understandings. 

Date: \ \U , By: 

Date: \ I \0 lc).OJ 3 By: 

By: 

Y LAPOINTE 

ATES ATTORNEY 

IS GATZ 

ASSIST ANT UNITED ST A TES ATTORNEY 

~ CAROLINE McCRAE 

ATTORNEY FOR DEFENDANT 

MAHANDRASOO'KRAM 

DEFENDANT 

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