Chapter 3: THE FORGED WILL — Raffi Ceylan Murder Evidence

FOUNDATION

THE FORGERY IS THE WILL.
ANYBODY CAN SEE IT.

A high-school student can look at the document and call it. The signs are on the page in front of you.

WHAT THE DOCUMENT ITSELF SHOWS

The document the court accepted as Raffi's will is — on its face — a forged instrument. The forensic features are visible without any expert. Francesco Longo's May 25, 2026 attestation:

"It's clear as day on there. Giant letters they say COPY, COPY, COPY all over it. And yet the names of the beneficiaries are stamped or typed on top of the word COPY. Ten-year-old brand new ink. With the wrong font sizes. And the fucking letters — I and R and A — they don't even match. Anybody can see that. Fraud from the very beginning."

Sign 1 · The COPY watermark

Giant COPY COPY COPY watermarking is printed across the document. A document watermarked “COPY” is by definition a duplicate, not an original executed will.

Sign 2 · Names typed OVER the watermark

Beneficiary names appear stamped or typed on top of the word COPY. The COPY watermark sits underneath the named text — meaning the names were applied to a document that was already watermarked as a duplicate.

Sign 3 · 10-year-old document, brand-new ink

The document is purportedly years old, but the beneficiary text sits in fresh ink on its surface. Ink dating is a recognised forensic discipline; this anomaly is testable in a lab.

Sign 4 · Wrong font sizes

The beneficiary text is set in different point sizes from the surrounding body text. An original typed instrument is consistent in font and point size throughout.

Sign 5 · The letters do not match

The letterforms of I, R, and A in the beneficiary text do not match the same letters elsewhere in the document. Forensic document examiners call this a typescript mismatch — evidence the beneficiary line was added by a different machine or insertion than the original document body.

THE LOGICAL IMPOSSIBILITY — WHAT NO RATIONAL MAN DOES

Even if every line of the document body looked perfect, the will would still fail the rationality test. Forensic document examination is one method of proving forgery. Documented testamentary intent is another — and on testamentary intent, this will fails completely.

Francesco Longo's May 25, 2026 attestation:

"Raffi goes through all this trouble to make sure they have a Separation Agreement — four copies, different versions, whatever. He even tries to have another relationship with her at one point. That didn't work out, so they go their separate ways again. Agreed: I'm going to separate ways. You pay for yours. I pay for mine. But the son gets everything. Ashton was granted everything."

"And on the last day, when he dies — are you telling me in that will he left absolutely nothing to his entire family? After all that trouble. His twin sister, nothing. His mom who lent him the money to get the business started — nothing. His brother who loved him so much — nothing. He left everybody nothing, huh? Not a dime. Not a single thing after all that trouble, all those years paying the lawyer to do this and paying the lawyer to make sure that bitch doesn't get a fucking thing. Praying. And she ends up with everything. Every fucking thing."

Under Canadian probate doctrine, a will is the testator's settled, considered, final expression of intent. Where the testator has spent years and thousands of dollars in legal fees documenting a specific contrary intent — the 2011 Separation Agreement excluding the ex-spouse from life insurance, the failed reconciliation, the renewed separation, the explicit naming of the son as the protected beneficiary — a will that reverses every one of those documented decisions is on its face suspect. When the same will also shows the physical forensic anomalies catalogued above, the inference is no longer suspect. It is forged.

THE PEOPLE RAFFI ACTUALLY LOVED — ALL DISINHERITED

The forged will leaves nothing to the people Raffi actually built his life around. The Separation Agreement, by contrast, names his son. The four people erased from the will are:

LUCY CEYLAN · twin sister

The person who has spent ten years pursuing the truth about her brother's death — ten years of police reports, Law Society complaints, audio recordings. Inherited: nothing.

BETTY (BERCHUI) CEYLAN · mother

The woman who lent Raffi the seed capital that started his business. The business whose corporate insurance policy generated the $607,228.70 Sun Life payout to Ivana. Inherited: nothing.

ARMIN CEYLAN · brother

Raffi's brother — described in Francesco's attestation as “the brother who loved him so much.” Inherited: nothing.

ASHTON CEYLAN · son

The single beneficiary the 2011 Separation Agreement was designed to protect. Years of legal fees were spent specifically to direct Raffi's estate to Ashton through life insurance. Inherited under the will: nothing — until a 2018 court order separately corrected this.

THE TEST A JUDGE CAN APPLY IN FIVE MINUTES

Look at the will. Is the word COPY printed across it as a watermark? Yes.
Are the beneficiary names typed on top of that watermark in fresh ink? Yes.
Do the letter shapes (I, R, A) in the beneficiary line match the rest of the document body? No.
Are the font sizes consistent? No.
Did the testator spend years documenting an opposite intent in a Separation Agreement? Yes.
Did the testator's entire family inherit nothing, while his ex-wife inherited everything? Yes.

Six yes-no questions. Six findings consistent with forgery. The remainder of this chapter documents what happened in the courts after this forged will was tendered as authentic.

BEFORE WE GET TO THE WILL

WHO IS
IVANA HRVATIN?

The estranged wife — with one detail almost everyone missed.

By July 16, 2016, Ivana Hrvatin had been estranged from Raffi Ceylan for years. A signed Separation Agreement existed and had been witnessed by Bart Seguin in November 2011. Under that agreement, Ivana's property and beneficiary rights against Raffi's estate had been revoked.

On the day Raffi died, Ivana was not living with him. She was not co-parenting with him. She was not financially dependent on him in any way the law would recognise.

She was, however, eight months pregnant.

THE FACT THAT REFRAMES EVERYTHING

She gave birth on August 9, 2016.
Twenty-four days after Raffi died.

The child was not Raffi Ceylan's. At the moment of Raffi's death she was carrying a baby fathered by another man.

By the time of the will reading on August 5, 2016, she was within days of delivering. By the time the family was given the unsigned facsimile, she had already given birth. By the time the Sun Life Transfer of Ownership was processed with a forged Crystal Staples signature on September 12, she was a new mother of a child Raffi had not fathered, holding herself out as Raffi's sole heir.

A visibly pregnant woman, separated for years, racing to inherit from the man whose name was not on her baby's birth certificate.

THE QUESTION THE EVIDENCE FORCES

A woman who is eight months pregnant by another man, estranged from her husband for years, and who suddenly has an entire estate apparatus ready to move on the day of her husband's death — is not improvising.

She is executing.

The pregnancy is the timeline. The timeline is the motive.

EX-RAFFI-AUD-CONFRONTATION-001 · 30 SECONDS

LUCY CALLED IVANA.
SHE RECORDED THE CALL.

Thirty seconds. One pickup. Lucy Ceylan reaches Ivana Hrvatin directly — the woman who, according to the public record, gave birth to another man's child twenty-four days after Raffi died and then swore under oath she was Raffi's sole beneficiary. Recorded under Criminal Code s. 184(2)(a) one-party consent.

LISTEN: LUCY CONFRONTS IVANA

From the January 2026 Master Audio Inventory (file 97 of 103) · Tier 2 corroborating admission.

AUGUST 5, 2016

THE WILL READING

Twenty days after Raffi's death — a bait-and-switch in Bart Seguin's office.

WHAT THE FAMILY SAW IN THE OFFICE

On August 5, 2016, Lucy Ceylan, her mother Betty Ceylan, and her brother Armin Ceylan sat in Bart Seguin's office at Shibley Righton LLP for the reading of Raffi's will.

Bart Seguin presented a Will. The family saw it. They were given a copy at the meeting.

SMOKING GUN #1 · THE SWITCH

They saw a signed Will.
They went home with an unsigned one.

When the family arrived home and looked at the copy Bart had handed them, they discovered something the office lighting had hidden:

No signatures.
No initials.
No witnesses on the page.

The Will they had been shown at the meeting was not the Will they had been given. The signed instrument they had seen in Bart Seguin's hands disappeared back into his office. What walked out the door with Lucy, Betty, and Armin was a blank facsimile.

The original signed Will has never been produced. Not in 2016. Not in 2026.
It exists nowhere but in the family's memory of one afternoon in August.

WHY THE SWITCH MATTERED

A signed Will can be authenticated. Signatures can be compared to known exemplars. Witnesses can be subpoenaed. The chain of custody can be traced.

An unsigned Will is paper. It proves nothing. It can be challenged, dismissed, ignored.

By giving the family an unsigned copy, Bart Seguin neutralised the one document that would have constrained what Ivana Hrvatin could later claim under oath.

THE PERJURED AFFIDAVIT

December 14, 2017 · Sworn under oath

EXHIBIT RC-003 — Ivana Hrvatin Estate Application 2017-12-14

On December 14, 2017, Ivana Hrvatin filed an Estate Application falsely claiming she was the sole beneficiary of Raffi's estate. The filing came five days after a settlement was reached establishing a different distribution.

Court Order March 13 2018 · Justice T.J. Carey · Ashton declared sole heir · Court File CV-17-25300 — **EXHIBIT RC-COURT-ORDER-MAR13-2018** · Ontario Superior Court of Justice · Court File **CV-17-25300** · The Honourable **Justice T.J. Carey** · entered at Windsor **March 13, 2018**. Order: "THIS COURT ORDERS AND DECLARES that Ashton Ceylan is the sole heir of Raffi Ceylan, and the sole person having a beneficial interest in the Estate of Raffi Ceylan." The Court further ordered that Ivana Hrvatin shall provide a financial update on an annual basis to Berchui (Betty) Ceylan — **an order Ivana has never complied with since the date of issue.** The Court Order directly contradicts Ivana's sworn Estate Application of December 14, 2017 in which she claimed to be the sole beneficiary. Click image to zoom.

VIEW THE PERJURED ESTATE APPLICATION (Dec 14, 2017)

Two documents. Three months apart. The first contradicts the second under oath.

On December 14, 2017, Ivana Hrvatin swore an affidavit.

In it, she claimed she had no knowledge of the 2011 Separation Agreement between herself and Raffi Ceylan.

She made that claim under oath to the Windsor Superior Court of Justice.

It was a lie.

EXHIBIT RC-MINUTES-OF-SETTLEMENT · DECEMBER 9, 2017

The Minutes of Settlement — signed at the Windsor courthouse on December 9, 2017. Five days before Ivana Hrvatin swore she was the sole beneficiary, this is the document she had already signed. Both her own lawyer (Barton J. Seguin) and Betty's lawyer (David M. Sundin) signed as witnesses. Section 9 states explicitly that an Order shall be obtained declaring Ashton the sole beneficiary. The red-pen annotation in the bottom margin is Francesco Longo's own hand-written attestation.

Minutes of Settlement · December 9 2017 · Signed by Ivana Hrvatin and witnessed by Sundin and Seguin · with Francesco Longo's red-pen annotation — **EXHIBIT RC-MINUTES-OF-SETTLEMENT** · Pages 2 and 4 of the Minutes of Settlement · Dated **9th day of December, 2017**. **Signatures (Page 4):** Berchui (Betty) Ceylan · Ivana Hrvatin · Witness David M. Sundin (Betty's lawyer) · Witness Barton J. Seguin (Ivana's lawyer). **Yellow-highlighted clauses (Page 2):** Section 9 "There shall be an Order within the Application declaring that Ashton is the sole beneficiary…" · Section 10(ii) "Ivana shall not take any compensation for acting as Trustee" · Section 10(iii) "Ivana shall provide a financial update on an annual basis to Betty." **Red-pen annotation (Francesco Longo, hand-written):** "Ivana to this day has never provided any accounting to my mother." The Dec 14, 2017 affidavit Ivana swore five days later directly contradicts the document she signed here. Click image to zoom.

HOW WE KNOW

The 2011 Separation Agreement exists. Raffi signed it. Ivana signed it. It was witnessed and commissioned in November 2011 — six years before Ivana swore she had "no knowledge" of it.

The agreement settled the division of marital assets — including the assets Ivana would later claim, as Estate Trustee, that she was entitled to inherit in full.

The document Ivana swore she had never seen
is the one document that proves she wasn't entitled to what she took.

THE LEGAL CONSEQUENCE

Criminal Code of Canada, s. 131(1):

"Subject to subsection (3), every one commits perjury who, with intent to mislead, makes before a person who is authorized by law to permit it to be made before him a false statement under oath or solemn affirmation by affidavit, solemn declaration or deposition or orally, knowing that the statement is false."

A perjured affidavit filed for estate-administration purposes engages s. 131 directly. The maximum penalty under s. 132 is 14 years' imprisonment.

THE COURT FILE

FOUR DOCUMENTS MISSING

A court clerk confirmed it on the record. A police officer admitted why.

WHAT WAS NOT IN THE COURT FILE

DOCUMENT 1

Mother's Affidavit

Status: NOT FILED

Betty Ceylan's sworn statement — never reached the court record despite being referenced.

DOCUMENT 2

Ivana's Affidavit

Status: NOT FILED

The very document Ivana swore on Dec 14, 2017 to obtain sole-beneficiary declaration — subsequently absent from the file.

DOCUMENT 3

Separation Agreement (Nov 2011)

Status: CONCEALED 1.5 YEARS

Four identical copies executed November 2011, witnessed by Bart Seguin. Hidden 2016-2017 during estate proceedings.

DOCUMENT 4

Formal Settlement Agreement

Status: REDACTED (BLACK MARKER)

The Dec 9, 2017 Minutes of Settlement — what survives in the court file is hand-redacted with black marker.

THE COURT CLERK CONFIRMED IT

"That is absolutely all the files pertaining to your brother's estate."

— Court clerk, file review, J. Estate Files

When Lucy Ceylan reviewed the estate court file, the clerk certified the contents as complete — with four critical documents either absent or hand-redacted.

OFFICER DAN CALL — THE ADMISSION

FILE: Call2 WPS Officer Dan — timestamp [03:10]

ACTOR: Officer Dan, Windsor Police Service

"Everything's been hidden from the courts as well. They have to hide it from the courts."

Legal significance: A Windsor Police officer — the very institution Lucy was reporting fraud to — confirmed on a recorded line that documents were being intentionally concealed from the court system.

The use of passive voice "they have to hide it" presupposes knowledge of who is doing the hiding and why.

This contradicts every subsequent claim that documents were "lost," "misplaced," or "never filed in error."

CROSS-REFERENCE — RAY HAMLIN

In the 88-minute Lucy/Ray Hamlin call [10:00–12:00], Ray (Lucy's ex-boyfriend, with insider knowledge of the Windsor legal network) confirmed:

"Separate agreement existed; they lied and hid it for 1.5 years."

Two independent recorded admissions — one from a Windsor police officer, one from an insider witness — corroborating the same conclusion: the concealment was deliberate, sustained, and coordinated.

THE PATTERN

Four documents missing. A court clerk certifying the gap. A police officer admitting the gap was engineered. An insider witness confirming the duration.

Documents do not vanish from court files by accident. Not four of them. Not for 1.5 years. Not with black marker through the survivor.

SEPTEMBER 13, 2017 → OCTOBER 6, 2017

THE MAGICAL DISCOVERY

A bluff. A panic. Four drafts that “suddenly” appeared.

SEPTEMBER 13, 2017 — THE BLUFF

On September 13, 2017, Lucy Ceylan sent a private email to Bart Seguin and Ivana Hrvatin. The contents implied she had access to information about the Separation Agreement they had been denying existed. She told no one she had sent it.

OCTOBER 2, 2017 — THE STORY HOLDS

Three weeks later, Bart Seguin called Lucy's lawyer David Sundin and confirmed his position one more time: the Separation Agreement “was not signed.” The same day Justice Howard signed a Timetable Order moving the matter forward.

SMOKING GUN #7 · THE COLLAPSE

OCTOBER 6, 2017

Four days after telling David Sundin the Separation Agreement was not signed, Bart Seguin reversed himself.

On October 6, 2017, Bart Seguin announced he had “found” all four drafts of the 2011 Separation Agreement in a storage box.

A lawyer who had spent a year denying the document existed produced four versions of it. They had been in storage the whole time. He had known where they were the whole time.

The bluff Lucy sent on September 13 reached him. Three weeks of resistance collapsed inside ninety-six hours.

WHAT THE TIMELINE PROVES

A lawyer who can produce four signed drafts on October 6 knew those drafts existed on October 2. He knew on September 13. He knew when Lucy and Betty sat in his office in November 2016. He knew when he told Roger Skinner the agreement did not exist.

Concealment is not forgetfulness. The four drafts were never lost. They were withheld.

THREE PROCEDURAL ANOMALIES

THE PROCEDURAL FRAUD

When the lawyers and the judge needed the perjury to hold, the rules bent around them.

SMOKING GUN #8 · THE COMMISSIONER

BART SEGUIN COMMISSIONED HIS OWN CLIENT'S PERJURY

Ivana Hrvatin's sworn affidavit — the document where she claimed she had no knowledge of the 2011 Separation Agreement — was commissioned by Bart Seguin himself.

Bart Seguin had personally witnessed the four drafts of the Separation Agreement in November 2011. He had admitted on Lucy Ceylan's recording, on November 10, 2016, that the agreement existed. He had “found” all four signed drafts in storage on October 6, 2017.

Six days later, on October 12, 2017, the same lawyer placed his Commissioner's stamp on an affidavit swearing the document did not exist.

A Commissioner of Oaths who knowingly takes a false oath is not a clerical witness. Under Ontario law it is professional misconduct and a separate offence enabling perjury.

SMOKING GUN #9 · THE JUDGE'S CARVE-OUT

JUSTICE HOWARD SECRETLY EXEMPTED THE DISCOVERIES

On October 3, 2017, Justice Paul R. Howard — founder of Shibley Righton LLP, the same firm employing Bart Seguin — signed the Timetable Order governing the entire litigation schedule.

Buried inside the Timetable Order was a single procedural carve-out: Examinations for Discovery were exempted — both before AND after mediation.

Lucy Ceylan and Betty Ceylan were never told they were entitled to discoveries. The exemption was not flagged. They never had the chance to cross-examine Bart Seguin or Ivana Hrvatin under oath.

Discoveries are the cross-examination mechanism that exposes perjury before trial. By exempting them, the Timetable Order eliminated the procedural step where Bart's and Ivana's sworn lies would have collapsed.

The judge who signed the carve-out founded the firm that employed the lawyer who needed the carve-out. Discoveries were not waived. They were not omitted. They were exempted.

SMOKING GUN #12 · THE 6-DAY CERTIFICATE

SIX DAYS WHEN THE STANDARD IS SIX WEEKS

Ivana Hrvatin's sworn affidavit was filed on December 14, 2017. The Certificate of Appointment of Estate Trustee was issued by the Ontario Superior Court of Justice on December 20, 2017. The name of the signing judicial officer on that Certificate is a matter of public record and will be published here as soon as the original is independently verified.

Standard Ontario estate-trustee certificate

~6 WEEKS

Ivana Hrvatin's certificate (perjured)

6 DAYS

A document set whose accuracy was challenged on Lucy's recording from November 2016 moved through the registry seven times faster than the routine baseline.

THE FORGERY IS THE WILL.ANYBODY CAN SEE IT.