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FILINGSeptember 27, 2026

1) DEFENDANT'S OMNIBUS MOTION FOR NEW TRIAL AND POST-CONVICTION RELIEF BASED ON NEWLY DISCOVERED EVIDENCE (EXHIBIT A) AND CUMULATIVE TRIAL AND CONSTITUTIONAL ERRORS (EXHIBITS B–J)

Case No. 05-2007-CF-048580-AXXX-XX — State of Florida v. Larry Donell Goodman, Eighteenth Judicial Circuit, Brevard County, Florida. The foundational pleading of this record: the Defendant's Omnibus Motion for New Trial and Post-Conviction Relief Based on Newly Discovered Evidence (Exhibit A) and Cumulative Trial and Constitutional Errors (Exhibits B–J). The exhibits are presented in order below, each in its own numbered section of this record: • Exhibit A — Newly Discovered Evidence (Sworn Statement) • Exhibit B — Todd Corey Deratany records • Exhibit C — "REFUSED" Speedy Trial Waiver • Exhibit D — Total Absence / Non-Disclosure of Discovery • Exhibit E — Trial Transcript Errors (Pages 228–229) • Exhibit F — Lack of Official Oath — Lawrence Johnston III • Exhibit G — Four (4) Unconstitutional / Illegal Sentences • Exhibit H — Peacock Transcripts • Exhibit I — Winter Motion Proceedings & Reassignment Outcome • Exhibit J — Ad-Hoc Verdict Form & Jury Instruction Modifications Entered into the record for public review.

Omnibus Motion — September 2026

THE RECORDSeptember 27, 2026

2) INDEX OF EXHIBITS — EXHIBIT PAGE

Eighteenth Judicial Circuit, Brevard County, Florida. Lower Tribunal Case No. 05-2007-CF-048580-AXXX-XX — Larry Donell Goodman v. State of Florida. Official index of exhibits A through J filed in support of the Omnibus Motion for New Trial and Post-Conviction Relief: (A) newly discovered sworn statement; (B) Todd Corey Deratany disbarment and legal misconduct records; (C) refused speedy trial waiver; (D) non-disclosure of discovery; (E) trial transcript pages 228–229; (F) correspondence regarding an official oath of office; (G) records of four sentences alleged to be illegal; (H) transcripts involving Judge Aaron J. Peacock; (I) the Winter motion proceedings and caseload reassignment order; and (J) the August 2026 verdict form and jury instruction record. Entered into the record for public review.

Index of Exhibits — Exhibit Page

EVIDENCESeptember 27, 2026

A) NEWLY DISCOVERED EVIDENCE (SWORN STATEMENT) — EXHIBIT A

State of Florida v. Larry Donell Goodman, Case No. 052007CF048580AXXX. Sworn Affidavit of Truth executed by Damien Jones before a notary public in Marion County, Florida on March 10, 2017, and filed with the Clerk of the Circuit Court, Brevard County on March 21, 2017. In the affidavit, Damien Jones states under oath that he and Kwesi Philpot committed the 2007 offense at 4555 Helena Drive, Titusville, Florida, and that Philpot falsely implicated Larry Goodman to police due to prior personal animosity. Jones states he contacted Goodman's brother, personally handed a notarized copy of his confession to the prosecutor in open court, and mailed copies to the Clerk of Court, yet the affidavit did not appear in the official case record for a period of years. Entered into the record for public review.

Newly Discovered Evidence — Sworn Statement (FINAL Copy)

EVIDENCESeptember 27, 2026

B) TODD COREY DERATANY — REPRESENTATION AND DISCIPLINARY RECORD — EXHIBIT B

Compiled record concerning attorney Todd Corey Deratany's representation of Larry Goodman and his subsequent disbarment. In Greenwood v. Secretary, Department of Corrections, the federal appellate record states Deratany told the court immediately before trial that he had not spent much time working on the case because he expected it to be resolved through a plea agreement. The post-conviction claim alleged ineffective assistance based on failures including failing to depose witnesses, failing to test the firearm for fingerprints/DNA, failing to interview potential witnesses, and failing to call exculpatory witnesses. Deratany testified at the Rule 3.850 evidentiary hearing regarding his representation. The State's three-year plea offer was reportedly withdrawn after Deratany contacted a supervisor in the State Attorney's Office, and the case proceeded to trial. The Florida Bar's December 1, 2011 Disciplinary Actions report confirms: Todd Corey Deratany, 503 5th Ave., Suite 102, Indialantic, was permanently disbarred effective immediately following a September 13, 2011 court order (admitted to practice 2007). Deratany failed to comply with the terms of a March 14, 2011 suspension order; in May 2011 he had been disbarred for 10 years. He was the subject of numerous disciplinary violations, including failing to maintain adequate communication with clients, failing to appear for a civil trial without notifying the court or client of a conflict with a pending criminal case, and making disparaging remarks about another defense attorney during a recorded conversation with an incarcerated former client. (Case No. SC11-976) Entered into the record for public review.

1. Florida Bar Disciplinary Report — Todd Corey Deratany 2. Todd Corey Deratany — Information 3. Summary for Todd 4. Notice of Appearance — Todd Corey Deratany

FILINGSeptember 27, 2026

C) "REFUSED" SPEEDY TRIAL WAIVER — EXHIBIT C

Section 4 of the record — the "REFUSED" Speedy Trial Waiver (Exhibit C). Entered into the record for public review.

1. Speedy Trial Summary Objection (FINAL Copy)2. Waiver of a Speedy Trial

FILINGSeptember 27, 2026

D) TOTAL ABSENCE / NON-DISCLOSURE OF DISCOVERY — EXHIBIT D

Case No. 05-2007-CF-48580, Circuit Court of the Eighteenth Judicial Circuit, Brevard County, Florida. Demand for Discovery filed August 28, 2007 by defense counsel Todd C. Deratany and Brooke Deratany Goldfarb of Deratany & Goldfarb, Attorneys at Law, on behalf of Defendant Larry Donell Goodman, pursuant to Fla. R. Crim. P. 3.220(a)(1), demanding the State disclose and permit inspection, copying, testing, and photographing of all discoverable information and material within fifteen days; furnished to the Office of the State Attorney, Brevard County. Notice of Discovery and Motion for Statement of Particulars filed September 12, 2007 by Shawn Reid, Counsel of Record for Defendant Larry Goodman, pursuant to Fla. R. Crim. P. 3.220, demanding disclosure of witness information, statements, tangible evidence, confidential informant material, electronic surveillance records, search/seizure documentation, expert reports, and exculpatory material — and requesting, pursuant to Fla. R. Crim. P. 3.140, a statement of particulars specifying as definitely as possible the factual allegations, time, and place of the charged offenses. Hand-delivered to the Office of the State Attorney on September 12, 2007. Entered into the record for public review.

1. Demand for Discovery — August 28, 2007 2. Demand for Discovery & Motion for Statement of Particulars — September 12, 2007 3. Summary for Lack of Discovery (Final Version)

EVIDENCESeptember 27, 2026

E) TRIAL TRANSCRIPT ERRORS (PAGES 228 AND 229) — EXHIBIT E

Summary of the Assistant State Attorney's closing argument to the jury, walking through the verdict form. The prosecutor specifically asked the jury to check Option A (guilty of Home Invasion Robbery) and specifically urged a finding under the special interrogatory that Larry Donell Goodman "actually possessed a firearm during the commission of this crime," relying on testimony from State witness "Justin." As an alternative theory, the prosecutor instructed the jury that even without finding Goodman personally carried a firearm, they should still check guilty of home invasion robbery under a principal theory because the alleged co-defendant carried a firearm. Lesser included offenses (robbery with a weapon, burglary, aggravated assault, assault, trespass, petit theft) were listed only to argue the State had proven the highest charge: home invasion robbery with a firearm. Entered into the record for public review. The accompanying image is published below.

Trial Transcript Pages 228–229 — Summary

THE RECORDSeptember 27, 2026

F) LACK OF OFFICIAL OATH — LAWRENCE JOHNSTON III — EXHIBIT F

Email response dated March 20, 2026 from the Office of the General Counsel, Public Records Unit, Florida Department of State, R.A. Gray Building, Tallahassee, Florida, in response to a March 12, 2026 public records request. The Department states it "has been unable to locate responsive records" for copies of the Oaths of Office for Judge Lawrence V. Johnston for the years 2006 through 2011. Entered into the record for public review. The accompanying image is published below.

Public Records Email Summary — Oath of Office Search (FINAL Copy)

THE RECORDSeptember 27, 2026

G) FOUR (4) UNCONSTITUTIONAL / ILLEGAL SENTENCES — EXHIBIT G

Case No. 05-2007-CF-048580-AXXX-XX, Circuit Court of the Eighteenth Judicial Circuit, Brevard County, Florida. Order Granting Motion to Correct Sentence: order signed by Circuit Judge Lawrence V. Johnston granting the motion to correct sentence in State of Florida v. Larry D. Goodman, filed in open court on March 12, 2009. Document Page #121 of the court file. Motion for Rehearing — Illegal Sentence: filed February 20, 2025 by attorney Dan Ripley (Ripley Whisenhunt, PLLC) on behalf of Defendant Larry D. Goodman, pursuant to Fla. R. Crim. P. 3.800(b)(1)(B), arguing the trial court's January/February 2025 order correcting an illegal 10-year mandatory minimum sentence to a 15-year mandatory minimum was itself improper, because sentencing discretion under the Habitual Violent Felony Offender statute (State v. Hudson, 698 So.2d 831) entitles the Defendant to a full de novo resentencing hearing rather than a unilateral correction — citing Heatley v. State, Edward v. State, and Galindez v. State. Entered into the record for public review.

1. Order Granting Motion to Correct Sentence — March 12, 2009 2. Order Granting Motion — March 5, 2026 3. Motion Granted in Part / Denied in Part — February 23, 2025

FILINGSeptember 27, 2026

H) PEACOCK TRANSCRIPTS — EXHIBIT H

Case No. 05-2007-CF-048580-AXXX-XX, Eighteenth Judicial Circuit, Brevard County, Florida. Status Hearing — July 15, 2025: transcript of the digitally recorded Faretta hearing before the Honorable Aaron J. Peacock, in which Larry Donell Goodman requested to represent himself pro se after firing his attorney. The Court found Goodman competent and intelligent and granted his request to proceed pro se, set the de novo resentencing hearing for August 12, 2025, and addressed Goodman's difficulties obtaining legal mail and filing access at the Brevard County Jail due to a prior restriction on pro se filings entered by Judge Lemonidis. The State noted its motion to take Goodman's fingerprints for comparison to his prior record ahead of the habitual violent felony offender resentencing. De Novo Resentencing Hearing — August 12, 2025: transcript before the Honorable Aaron J. Peacock. Goodman, proceeding pro se, argued that the original sentencing judge, Lawrence V. Johnston III, lacked a valid oath of office (having retired in 1998), that the habitual violent felony offender (HVFO) finding required a jury determination under Apprendi v. New Jersey, Blakely v. Washington, and Erlinger, and that any increase to his sentence upon resentencing would violate double jeopardy. The Court denied the motion to dismiss, found no need to reopen the HVFO determination since it had already been made and upheld on appeal, and declined to exercise discretion against habitual offender sentencing. The Court sentenced Goodman to thirty years and a day with a fifteen-year mandatory minimum as a habitual violent felony offender — an increase from the original ten-year minimum mandatory found illegal — with credit for time served. Goodman was granted thirty days to appeal. Entered into the record for public review.

1. Status Hearing Transcript — July 15, 2025 2. De Novo Resentencing Transcript — August 12, 2025

FILINGSeptember 27, 2026

I) WINTER MOTION PROCEEDINGS & REASSIGNMENT OUTCOME — EXHIBIT I

Case No. 05-2025-CF-034362-AXXXBC, Circuit Court of the 18th Judicial Circuit, Brevard County, Florida — State v. Donovan Winter. Motion for Disqualification of Trial Judge: filed September 4, 2025 by defense counsel Sean Conway on behalf of Defendant Donovan Winter, seeking disqualification of "acting" Circuit Judge Aaron J. Peacock, arguing that successive 60-day administrative orders assigning County Court Judge Peacock to preside solely over Circuit Court felony cases — without ever assigning him any County Court cases — for 27 consecutive months of his 33-month term created a de facto, unauthorized Circuit Court position under Florida Supreme Court precedent (Crusoe v. Rowls, Wild v. Dozier, Payret v. Adams). The Defendant, charged with Felony Murder and Aggravated Child Abuse, submitted a sworn affidavit stating he feared he would not receive a fair trial before a judge not duly authorized to preside under established case law. Order Denying as Moot — Motion for Disqualification: order entered September 12, 2025 by Circuit Judge Charles G. Crawford, denying the motion as moot, citing Eighteenth Judicial Circuit Administrative Order No. 25-33-B — which, signed by Chief Judge Melanie Chase, reassigned Judge Peacock's entire pending caseload to Judge Crawford effective September 5, 2025, one day after the disqualification motion was filed and before it was ever ruled on for legal sufficiency. Entered into the record for public review.

1. Court Case — State v. Donovan Winter 2. Winter Motion — Denial Order 3. Winter Exhibit Summary (FINAL Copy)

EVIDENCESeptember 27, 2026

J) AD-HOC VERDICT FORM & JURY INSTRUCTION MODIFICATIONS — EXHIBIT J

Case No. 2007-CF-48580, Eighteenth Judicial Circuit, Brevard County, Florida — State of Florida v. Larry Donell Goodman. Transcript and analysis of an August 17–18, 2026 ad-hoc jury proceeding convened in connection with Mr. Goodman's post-conviction/resentencing history. Defense counsel raised a strenuous, continuous objection to the proposed "Statement of the Charge" instruction, arguing that the date of the underlying offense was an element the jury alone was entitled to determine, and that treating it as already established by the 2008 conviction would improperly remove a factual question from the jury's province while relieving the State of its burden of proof. The State argued the offense date was inherent in the 2008 jury verdict. The Court stated it tended to agree with the State "at least at this juncture," while acknowledging legal ambiguity and expressly preserving the defense objection for higher-court review. The record also documents disputes over the treatment of prior-conviction and fingerprint-card evidence under judicial notice versus formal exhibit admission, and confirms jurors were not to receive written copies of the jury instructions until deliberations began. Entered into the record for public review.

1. Transcription & Analysis — August 17–18, 2026 2. Ad-Hoc Summary — State of Florida v. Larry Donell Goodman

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