UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 22-CR-80146-CANNON 

UNITED STATES OF AMERICA 

vs. 

MAHANDRA SOOKRAM, 

Defendant. 

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

FACTUAL PROFFER 

The United States Attorney's Office for the Southern District of Florida and 

MAHANDRA SOOKRAM (hereinafter the "defendant") agree that had this case 

proceeded to trial, the United States would have proven the following elements and facts 

beyond a reasonable doubt: 

ELEMENTS 

1. The defendant attempted to bring an alien into the United States; 

2. The defendant knew at the time of the attempted entry that the person was 

an alien; 

3. The alien had not received prior official authorization to enter; and 

4. The defendant knew, or recklessly disregarded, the fact that the alien had 

no prior authorization to enter. 1 

1 "Reckless disregard" means deliberate indifference to facts which, if considered 

and weighed in a reasonable manner, indicate the highest probability that the alleged aliens 

were in fact aliens and were in the United States unlawfully. 

Case 9:22-cr-80146-AMC Document 23 Entered on FLSD Docket 01/11/2023 Page 1 of 3
FACTS 2 

1. On August 31, 2022, law enforcement officers ("Officers") observed the 

defendant MAHANDRA SOOKRAM ("SOOKRAM") piloting a vessel (the "Vessel"), 

that contained six passengers, approximately 20 nautical miles east of the Lake Worth Inlet, 

within the Special Maritime and Territorial Jurisdiction of the United States. The Vessel 

was thereafter interdicted by Officers in the vicinity of Lake Worth Inlet. Defendant 

SOOKRAM was questioned and advised Officers that he was a U.S. Citizen, while the six 

passengers reported that they were Guyanese nationals. 

2. Then, Officers reviewed the GPS device located on the Vessel, which 

revealed that the Vessel departed from a Marina located in Palm Beach County, Florida, at 

approximately 6:40 a.m. that morning, and arrived at the Old Bahama Bay resort at West 

End, Bahamas at approximately 9:40 a.m. the same day. The GPS device further revealed 

that at approximately 8:05 p.m. the same day, the Vessel departed West End, Bahamas and 

traveled due west towards the United States, ultimately being stopped in the vicinity of 

Lake Worth Inlet at approximately 10:15 p.m. 

3. As part of the investigation, Officers conducted database checks concerning the 

six Guyanese nationals located on the Vessel and discovered that none of the six individuals 

applied for, or received permission to, enter the United States. 

4. A review of the cellular telephone seized from defendant SOOKRAM's person 

revealed text message communications between himself and others in which defendant 

SOOKRAM discussed transporting individuals to the United States from the Bahamas, for a 

fee per person. Several of the text message exchanges were linked to one or more passengers 

Case 9:22-cr-80146-AMC Document 23 Entered on FLSD Docket 01/11/2023 Page 2 of 3
located on the Vessel on August 31, 2022. 

5. All events occurred in the Southern District of Florida and elsewhere. 

Date:I l /0 P 3 By: 

By: 

Date: \/IO /.2023 By: 

MARKEZY LAPOINT 

UN D STA TES ATTORNEY 

LA'. TREINIS GATZ 

ASSISTANT U.S. ATTORNEY 

C~E 

ASSISTANT FEDERAL PUBLIC DEFENDER 

MAHANDRASOOKRAM 

DEFENDANT 

3 

Case 9:22-cr-80146-AMC Document 23 Entered on FLSD Docket 01/11/2023 Page 3 of 3