There was no will.
They made one — and the ink sits on top of the COPY stamp.
Raffi Ceylan never signed a Last Will and Testament. No witness ever saw him sign one. The document the Defendants produced — dated 11 November 2007, purportedly witnessed by Barton J. Seguin and Paula Seguin — was manufactured after the fact, then used in 2016 to redirect CAD $607,228.70 of his corporate Sun Life proceeds to an ex-wife he had legally excluded by a 4-draft Separation Agreement. One visual fact on the face of the photocopy the Defendants themselves produced settles it without any expert, any colour original, and any Norwich Pharmacal disclosure.
A real 2007 will typed on blank paper, then stamped COPY when later photocopied, would show the COPY stamp on top of the text. On this document the opposite is visible. The inserted name-block — IVANA CEYLAN, ELENA O'NEILL, LYDIA ANNA HRVATIN — sits on top of the COPY stamp. The stamp is under the text.
That layering is physically possible only if the stamp was on the paper first and the name-block was typed onto the already-stamped page afterward. A 2007-signed original cannot produce that layering. Only a 2016-or-later fabrication can.
This finding does not require the colour original, Rule 11-6 expert evidence, or Norwich Pharmacal disclosure. It is on the face of the photocopy Defendant Ivana Hrvatin herself produced to the Ceylan family in 2016.
Four further face-of-document irregularities (ink colour · font · ink freshness · border overlap) are pleaded under oath at PASS15 § B.4 through B.7. The cumulative effect is a prima facie case under Criminal Code s. 366 that the Impugned Will is a false document and void ab initio.
This page is Raffi Ceylan's case, told from the record. The pleading is BCSC Vancouver. The affidavit is sworn. The signatory, Francesco Giovanni Longo, is named co-plaintiff alongside Lucy Ceylan (Raffi's twin sister), Armin Ceylan (Raffi's brother), and Betty Ceylan (Raffi's mother). What follows is what they pleaded under oath to a Canadian court.
Continue the narrative → Download the 12-page document (PDF · 5.4 MB) ← Nine-screen CPT explainer
Raffi Ceylan spent his life providing.
Then he became dead weight for the ex-wife.
Raffi Ceylan was a Windsor-origin businessman, owner of Northern Exposure (his corporation holding the Sun Life policy), and twin brother of Lucy Ceylan. His adult life was a continuous pattern of financial provision for his family — his twin sister, his brother, his mother, and his minor son. That pattern is the baseline against which the last-minute disposition was measured and found absurd.
The real family — the people the will disinherited
The people the forged Will named in the freshly-inked block
A person does not spend 2012-2016 financially supporting a twin sister, a brother, and an elderly mother, execute a 4-draft Separation Agreement explicitly excluding an ex-wife, reconcile briefly for the sake of a minor son, watch that reconciliation fail a second time, and then quietly produce — after his death — a Last Will and Testament that hands everything to the ex-wife and nothing to anyone else. That is not behaviour. That is forgery.
Raffi did not draft this once.
He drafted it four times.
Between the start and finish of the 30 November 2012 Separation Agreement, Raffi Ceylan required his solicitor, Barton J. Seguin of Shibley Righton LLP, to prepare and re-prepare the document in 4 successive drafts. Only when the fourth draft achieved the single operative outcome he was after — the complete exclusion of his ex-wife Ivana Hrvatin from any spousal share of his insurance, corporate, or personal assets — did he execute it. The executed Agreement was witnessed by Barton J. Seguin and his wife Paula Seguin (on information and belief, Ivana Hrvatin's close personal friend of 30 years).
BETWEEN Ivana Hrvatin of the City of Windsor (First Part) AND Raffi Ceylan of the City of Windsor (Second Part). On this document Ivana had reverted to her maiden name Hrvatin. One of 4 witnessed drafts produced by Seguin on Raffi's adamant re-drafting instruction.
“4 drafts of a Separation Agreement is not consistent with a drafter merely transcribing a single settled instruction. It is consistent with a testator/separator who was adamant, over the course of the drafting process, that each draft achieve a single operative result: the complete exclusion of Ivana Hrvatin from any spousal share of his insurance, corporate, and personal assets.” PASS15 Affidavit · Section C.2 · sworn
Why 4 drafts is legally decisive
The 4-draft record is pleaded both as independent evidence of settled intent and as a second independent indicator (alongside the ink/font/border forensics on the Will itself) that the Impugned Will is a forgery.
Rational human conduct
does not do this.
The sworn foundation of this entire case is not a legal theory. It is a narrative impossibility. Exhibit B21 of the filed pleading package puts Francesco Longo's voice directive from 27 April 2026 on the record as sworn evidence. It is quoted here verbatim.
“He went through all that trouble to make sure he had. We have to take care of them, their own selves. Me — when he dies, he decides at the last minute to give everything to that bitch. Look at the storyline... his wife, which she divorced. And gave a second try to. And wanted to see if it would work out for the benefit of the child. And then after that decide to give her everything. Nothing to his twin sister. Brother. And nothing to his mother.” Francesco Giovanni Longo · voice directive 27 April 2026 ∼ 12:15 EDT · Exhibit B21
The narrative arc — pleaded at Exhibit B21 Section 3
The legal characterisation
“Rational human conduct does not go: sign a formal Separation Agreement excluding my ex-wife → spend a decade supporting my sister, brother, and mother → tell my lawyer on tape my son should get the money → then at the last minute silently direct my insurance proceeds to the ex-wife I had legally excluded, bypassing the son, the sister, the brother, and the mother. No such testator exists in life.” PASS15 · Exhibit B21 · Section 4
Legal authorities pleaded: Wills Variation Act, R.S.B.C. 1996, c. 490 · Vout v. Hay, [1995] 2 S.C.R. 876 (undue influence · suspicious circumstances) · Pettkus v. Becker, [1980] 2 S.C.R. 834 · Soulos v. Korkontzilas, [1997] 2 S.C.R. 217 (constructive trust) · Performance Industries v. Sylvan Lake Golf & Tennis Club, 2002 SCC 19 (fraudulent concealment · tolling of limitation).
Raffi Ceylan never signed a will.
The document they produced is a forgery of the whole instrument.
This is the central factual claim, and it is pleaded on oath. There was no executed Last Will and Testament of Raffi Ceylan. Raffi did not sign one. No witness saw him sign one. The document Defendant Ivana Hrvatin caused to be produced to the Ceylan family — dated 11 November 2007, bearing the purported witness signatures of Barton J. Seguin and Paula Seguin — was manufactured after the fact, as a forgery of a document that never legally existed.
“The will was never signed by Raffi Ceylan or anybody. There was never a will. They had to forge it and make it themselves. Whatever they put on there is fake. The fact that it was done years ago and has fresh ink on it, with the wrong typewriter and the wrong font sizes — is proof enough.” Francesco Giovanni Longo · directive 1 May 2026 · on the forgery framing
A document that claims to have been typed and signed on 11 November 2007 cannot, in 2026, still display fresh ink, multiple typefaces from different mechanical instruments, inconsistent stroke weight, and overwrite-overlap on its name-block. A document from 2007 is nearly twenty years old. The ink in its original ribbon strike has had two decades to dry and oxidise. It cannot then present with the saturation and sharpness of a recent typing pass. The four face-of-document irregularities pleaded below are not artefacts of age or handling. They are the mechanical signature of a recently-produced forgery bearing a back-dated 2007 creation claim.
The document itself · photocopy on file · from Lucy Ceylan's 24 January 2026 email
What follows is two pages from the 12-page document the Defendants produced as the purported Last Will. This is a black-and-white photocopy (the original with the ink-shade differential is held by the Defendants and will be compelled under the Norwich Pharmacal Order). Even on the photocopy, the backing structure of the forgery is visible: the witness signature block on page 12 does not match the names that appear on the body pages, and the beneficiary name-block on page 11 displays noticeably higher contrast than the surrounding prose.
The all-caps name-block — IVANA CEYLAN, ELENA O'NEILL, and LYDIA ANNA HRVATIN — is what PASS15 § B.4 describes as the “inserted name-block in distinctly darker black ink.” The affidavit references Ivana Hrvatin by her maiden name (as she appears on the 2012 Separation Agreement after reversion) though the document here types it as her married name Ceylan.
Dated 11 November 2007. Witnesses: BARTON J. SEGUIN (c/o Bartlet & Richardes, 1000-374 Ouellette Avenue, Windsor) and PAULA SEGUIN (1665 Normandy, LaSalle). The Plaintiffs plead that none of these three signatures — Raffi Ceylan's, Barton J. Seguin's, Paula Seguin's — were in fact made in 2007. The signature block is part of the same manufactured document the body pages are.
The Plaintiff's own annotated view · the sequencing error that proves the whole thing
Francesco Giovanni Longo marked up this page directly. The yellow note at top-left identifies what the eye picks out immediately: "letter I is clearly wrong font type and ink is fresh · ink type is also on top of the word COPY." The red annotations circle each instance of IVANA CEYLAN, ELENA O'NEILL, and LYDIA ANNA HRVATIN, and the red arrows pick out the paragraph marker (l) where the character is drawn from a different typeface than the surrounding body text.
Yellow: "letter I is clearly wrong font type and ink is fresh / ink type is also on top of the word COPY." Red circles: each instance of the inserted names. Red arrows: the paragraph marker (l) drawn in a different typeface.
A will that was actually typed in 2007 on a blank sheet of paper, and then stamped with a COPY watermark at some later date when photocopies of the original were produced, would show the COPY stamp on top of the typed text. The typed text is the substrate. The stamp comes later. That is the physically obligatory sequence.
On this document the opposite is visible. The inserted name-block letters — visibly darker, in a different font, with fresh-ink characteristics — sit on top of the COPY stamp. The stamp is under the text. That is only possible if the stamp was on the paper first, and the name-block was typed onto the already-stamped page afterward. Which means: the Defendants took a pre-stamped COPY of something, fed it back into a typewriter, and typed the forged name-block onto it. A 2007-signed original, copied in 2016 and again in 2026, cannot produce that layering. Only a 2016-or-later fabrication can.
This is a sequencing proof. It does not depend on expert opinion, on colour spectroscopy, or on the Norwich Pharmacal Order. It is on the face of the photocopy the Defendants themselves produced.
Download the full 12-page document (PDF · 5.4 MB)
The four sworn irregularities · each sufficient on its own
Ink-colour & saturation mismatch · PASS15 § B.4
“Distinctly darker black ink than the surrounding text.” The name-block letters carry mechanically darker ink than the adjacent paragraphs. On an originally-typed 2007 document, ribbon strike is uniform across a single typing session. Different ink saturation means different sessions — i.e., an insertion made at a later time, not at original drafting.
Font & letter-thickness mismatch · PASS15 § B.5
“Typeface, stroke width, and letter-spacing materially different from the balance of the document.” The name-block characters do not come from the same mechanical typewriter as the surrounding paragraphs. A single 2007 typing session cannot produce two different typefaces.
Ink-freshness anomaly · PASS15 § B.6
“The ink forming the inserted name-block appears fresh — saturated and sharply bordered — in a manner inconsistent with the represented age of the document.” A document claiming a 2007 creation date cannot, in 2026, still present with fresh-ribbon ink characteristics. Nearly twenty years of drying, oxidation, and paper absorption leave visible traces. The absence of those traces is the tell.
Border-overlap · PASS15 § B.7
“The inserted letters visibly overlap and thicken against surrounding characters — visually inconsistent with a single original typing pass.” Characters typed on a different mechanical pass collide with their neighbours where a clean single-pass typing would preserve uniform spacing. This is the physical signature of an overwrite.
Those four visible features, in combination, are sufficient to establish a prima facie case that the Impugned Will is a false document within the meaning of Criminal Code s. 366. The Plaintiffs rely on R. v. Trochym, 2007 SCC 6, for the proposition that on-face documentary irregularities of this nature do not require expert opinion for a Court to decline to give the document face-value authority. The Impugned Will is void ab initio.
A Rule 11-6 forensic-document-examiner report is reserved for the merits stage. On compelled disclosure under the Norwich Pharmacal Order, the original document — not a photocopy — will be subjected to professional Questioned Document Examination: ink-differentiation spectroscopy, typeface identification against the known typewriters at the relevant office in 2007, spacing and border-overlap measurement, and paper-age testing. Every one of the four face-of-document irregularities will be independently confirmable.
CAD $607,228.70.
To the excluded ex-wife.
The forged Will was the paper. The Sun Life Transfer of Ownership was the instrument. Sixty-five days after Raffi Ceylan's documented death, Sun Life Assurance Company of Canada — acting through its named agent Bill Benson — processed the transfer of the policy from Northern Exposure (Raffi's corporation) to Ivana Hrvatin personally, on a Transfer of Ownership bearing the forged signature of Crystal Rivard, Northern Exposure's financial signing authority.
The recorded admissions
At timestamp 83:00 of a recording preserved in Lucy Ceylan's possession, Bill Benson is heard making a statement amounting to an admission that the Will was a forgery. Prior to that point in the recording, Benson repeatedly told the family Raffi had died without a Will. The family in fact held an unsigned 11 November 2007 Last Will and Testament, and later received a signed copy from Ivana Hrvatin herself — not from Bart Seguin, Raffi's solicitor.
Seguin states to Lucy: “There's no cheque going to her and her name. The money stays with the corporation until Revenue...” — directly inconsistent with the Hrvatin Transfer Sun Life had already processed 58 days earlier. Seguin either did not know what his own client's estate had done, or was actively misrepresenting a transaction he knew had occurred.
Crystal Rivard is the Officer and financial signing authority of Northern Exposure, Raffi Ceylan's corporation. She has personally confirmed to the Plaintiff Francesco Longo that the signature on the 12 September 2016 Sun Life Transfer of Ownership is forged. She is not a party to this action. She is the factual witness whose evidence puts the last mechanical link of the fraud on the record.
The subsequent concealment — redactions by Sun Life
After the Hrvatin Transfer was processed, Bill Benson caused critical information to be redacted from the Transfer of Ownership document before any copy was released. The redactions themselves are consciousness of guilt — Sun Life choosing to withhold parts of a document it had already executed.
The evidence existed.
It was hidden for 18 months.
Ordinary estate fraud unravels in weeks. This one held for 9 years because a coordinated chain of actors — solicitor, insurer, coroner, police — each did the one small act needed to keep the sworn record out of the family's hands until the limitation clocks had started to run. Every act in this chain is pleaded as a distinct offence.
The 18-month concealment · Separation Agreement
The Impugned Will · a different concealment
At the reading of the Will, Seguin furnished the Ceylan family with only an unsigned copy. The family demanded a signed copy over several weeks. Seguin denied possessing one and directed them to Ivana Hrvatin — the sole person said by Seguin to hold signed copies. The family ultimately obtained the signed copy from Ivana herself. A solicitor directing a dead client's family to the person who benefits from the disputed instrument is a fiduciary-duty breach on its face.
The laptop · 3 weeks after death
Approximately 3 weeks after Raffi Ceylan's death, in the first or second week of August 2016, contemporaneous with the forced departure of Julie Triferis (Raffi's domestic partner, non-party) from the Ceylan residence, Bart Seguin attended at the residence, required Ms. Triferis to surrender her keys, and — in or about that same period — Raffi's personal laptop went missing. On information and belief, corroborated by Ms. Triferis's account, Seguin wrongfully took possession of the laptop. It has never been returned. It is the subject of the conversion / detinue claim at Ground 4.
The police · 3 investigators · 10 years of refusal
At transcript time-mark ~2:04:00 Potvin stated: “that forged document that you guys are alleging — leave that one with me.” At ~2:26:00 he stated: “three separate investigators looked at this... everyone is saying this is a civil situation.” Three Windsor Police investigators examined the forgery allegation. Each declined to proceed. Potvin agreed on the recording to obtain the Sun Life document in unredacted form and thereafter sabotaged that undertaking.
At timestamp 12:20 on a recording in Lucy Ceylan's possession, Sgt. Renaud threatened Lucy in words to the effect “there will be consequences” for reporting the conduct pleaded in this action.
This is not an estate fraud.
It is an organisation, by law.
The Plaintiffs plead the conduct chain under Criminal Code s. 467.1 — the criminal organisation provision — because the architecture is not a lone lawyer and a lone ex-wife. It is a repeat pattern of concealment, across three distinct victims, operated through a single law firm, protected by a bench-spouse relationship, gate-kept at the Law Society, and silenced at the local police service.
The Shibley Righton concealment quartet
The s. 467.1 three-case interlock
The same concealment architecture — Shibley Righton + Bart Seguin + Bill Benson + Ivana/affiliated family networks — operates across three separate victim cases: Lucy Ceylan (Raffi estate fraud, 2016-2026), Dave Simetic (separate estate-fraud pattern match), and Francesco Longo (21-year transnational wrongful detention cascade). The three cases share the lawyer, the firm, the witness-signing pattern, and the downstream Windsor Police silencing. That is what Criminal Code s. 467.1(1) means by “criminal organisation” — and what R. v. Venneri, 2012 SCC 33, confirms is satisfied by a repeat-pattern structure spanning multiple predicate offences.
Selected defendants on the roster · BCSC NOCC v4
Full roster, numbered paragraphs, and pleaded conduct: Notice of Civil Claim v4, BCSC Vancouver Registry · signed Pass 15 Affidavit of Francesco Giovanni Longo · exhibits B18 (Autopsy Forgery Temporal Impossibility), B19 (Bart Seguin 16 Nov 2016 Tape), B21 (Raffi Disposition Absurdity), B22 (Lucy Ceylan Shibley Righton Conspiracy), B25 (TRIFECTA Master Index), B26 (SCC Registry Acknowledgement 9 Mar 2026).
This is sworn.
This is filed.
The registry has acknowledged.
Everything on this page is in a Canadian court file. The Plaintiffs are Francesco Longo, Lucy Ceylan, Armin Ceylan, and Betty Ceylan. The affidavit is signed, sworn, and deposed. The Supreme Court of Canada has already acknowledged receipt via registry letter dated 9 March 2026. The proceeding is live.
The Ashton Beneficiary Order · and the 8-year void
An Order declared Ashton Ceylan — Raffi Ceylan's minor son — the sole beneficiary of the Ceylan estate. Ivana Hrvatin was named trustee with zero compensation. In the 8+ years since the Order was made, no accounting, no statement, no reconciliation, no proof of any kind of the trust fund held for Ashton's benefit has ever been produced to the Ceylan family. The Sun Life Transfer proceeds and the undisclosed Empire Life proceeds — each of which ought to have been paid into the Ashton trust — were diverted away from that trust by the exact conduct chain pleaded on this page.
What the Norwich Pharmacal Order will compel
- The original Impugned Will — certified colour copy — for Rule 11-6 Questioned Document Examination (ink, typeface, border-overlap confirmed under oath)
- The Sun Life Transfer of Ownership — unredacted — with the forged Crystal Rivard signature preserved for expert comparison
- The Empire Life policy file — the ~$10M+ instrument never disclosed to estate, coroner, or police
- The Shibley Righton file on Raffi Ceylan — including the 4 drafts of the Separation Agreement with their creation timestamps
- The Ashton trust-fund records — every deposit, every withdrawal, every statement from 2018 to present
What the Mareva Injunction asks the Court to freeze
All assets of Ivana Hrvatin, her nominees, her corporations, and any third-party recipient with notice of the Hrvatin Transfer, pending determination of the constructive-trust claim over the CAD $607,228.70 and its accrued returns (investment and other) from 19 September 2016 to date.
The record, stripped of rhetoric
A testator does not execute a Separation Agreement in 4 drafts to exclude an ex-wife and then draft a Will giving her everything. A solicitor does not hide the Separation Agreement from the grieving family for 18 months for any legitimate reason. A bank agent does not accept a forged corporate-officer signature on a $607,000 transfer and then redact the proof. A Windsor Police superintendent does not tell a complainant on tape to “leave the forgery with me” and then sabotage the disclosure he promised. A Regional Supervising Coroner does not communicate case details directly with the murder suspect via the suspect's lawyer's letterhead while excluding the surviving twin sister who is legal family representative. Each act is either a dereliction or a coordination. Considered in aggregate, only coordination remains as a rational explanation.
This page is a public summary of the sworn pleading. Where this page and the affidavit differ, the affidavit rules. Every factual claim is paragraph-citable to PASS15 Affidavit of Francesco Giovanni Longo, Sections B, C, F, G, H, and Exhibits B18, B19, B21, B22, B25, B26.
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