CHAPTER FIVE
Shibley Righton LLP · the law firm representing both sides
One firm. One judge. One pattern. Ten years of cover.
The structural centre of the Ceylan estate fraud
Every major decision in the Raffi Ceylan case passes through one law firm: Shibley Righton LLP.
It is the firm that witnessed the agreement Ivana later denied existed. It is the firm whose founder sat as the judge who granted the perjury-secured Certificate of Appointment in six days. It is the firm whose lawyers represented adverse parties in the same matter without disclosure.
One firm. Three roles. No disclosure.
Named perpetrators · each with a defined role
Shibley Righton LLP · Estates and Family Law
November 2011: Witnessed and prepared the Separation Agreement between Raffi Ceylan and Ivana Hrvatin.
2017: Failed to disclose the existence of the 2011 Agreement to the estate court — despite holding the original.
November 16: Caught on tape — the conspiracy bridge recording (next chapter).
Windsor Superior Court · Shibley Righton LLP founder
December 20, 2017: Granted Certificate of Appointment in six days · undisclosed conflict.
March 13, 2018: Blocked Rule 31 examinations · erased Lucy's ability to question Ivana under oath.
January 15, 2026: Same judge surfaces in the Miceli defamation matter in the Windsor Star article on Armin Ceylan's arrest — pattern evidence.
McTague Law Firm · Lucy Ceylan's former counsel
Role: Retained to represent Lucy. Switched sides. Recorded admitting it.
Connection: Mayor Drew Dilkens is former McTague Law Firm + current Police Board Chair — pattern evidence of overlapping institutional roles.
Windsor lawyer · personal connection to Ivana Hrvatin
On the record: "I'm not willing to risk my career for you."
On the record: "I went to school with Ivana."
Combined effect: Personal conflict of interest plus career-protection refusal — institutional coercion proven on tape.
The Planted Mediator · An active judge who shouldn't have been there
SMOKING GUN #10 · THE PLANTED MEDIATOR
Mary Jo Nolan was the “neutral” mediator on the Ceylan estate case. She had been recommended to Lucy by lawyer David Sundin as “a retired judge with no connections.”
Three undisclosed conflicts of interest:
1. Per the Law Society of Ontario's own records, Mary Jo Nolan was NOT retired. She was registered as ACTIVE AS A JUDGE at the time she was mediating the Ceylan case as a private mediator.
2. Her mediation office is in Suite #301 — the same suite as Shibley Righton LLP, the firm representing one of the parties.
3. Her husband, Brian Nolan, is a Senior Partner at Shibley Righton LLP.
A sitting judge. Mediating a case. Inside her husband's law firm's office. None of it disclosed.
EX-RAFFI-AUD-006
Law Society Agent Noe — Active-Judge Status Confirmed
Lucy → LSO callback · recorded admission
Agent Noe verbatim: “According to our records, Mary Jo Nolan shows as active as a judge.”
Listen to the LSO recording →
WHAT HAPPENED INSIDE THE MEDIATION
A full transcript of the third Ceylan estate mediation session, conducted under Mary Jo Nolan's “neutral” mediator role — while she was actively registered as a judge per the Law Society's own records, and while her husband was a Senior Partner at the law firm representing the opposing party.
On the record:
This is the transcript that captures the planted mediator's machine in operation — 70 minutes, 64.9 MB, every word.
READ THE MEDIATION 3 TRANSCRIPTTHE ORCHESTRATOR · THE INFORMATION HUB
Why this conspiracy required Bart Seguin specifically — and how Paula Seguin made the channel possible.
A plot to seize Raffi Ceylan's estate could not have been executed by Ivana alone. It required a single person who held simultaneous knowledge of Raffi's business, his corporation, his will, the 2011 Separation Agreement, and the existence and beneficiaries of every life-insurance policy.
Only one person had all of that information. Raffi's lawyer.
ACTOR 1 · MOTIVE
IVANA HRVATIN
Raffi's wife
Stood to gain $708,981.66 in combined life-insurance proceeds plus real property. Direct financial motive.
ACTOR 2 · CHANNEL
PAULA SEGUIN
Bart Seguin's wife
30+ years best friends with Ivana — since teenagers, possibly since grade school. Paula also signed Raffi's will as a witness.
ACTOR 3 · ORCHESTRATOR
BART SEGUIN
Raffi's lawyer · Shibley Righton LLP
Raffi's close personal friend for years AND his lawyer. Knew the business, corporation, will, separation agreement, all insurance policies. Sole holder of complete information.
ACTOR 4 · ON THE GROUND
DARYL LAUZON
Raffi's grade-school best friend
First person through the bedroom door at Chapleau. Co-owner of Windsor property with Raffi (per 2013 Transfer Tax Statement). Physical presence at the death scene.
Ivana ↔ Paula
Best friends for 30 years. Personal channel. Ivana's frustrations, complaints, expectations — including any statement that she would never see her share of Raffi's estate — flow naturally through this 30-year friendship.
Paula → Bart
Marriage. Conversations at home. The wife's 30-year best friend's family situation becomes household knowledge for the husband — the husband who happens to be Raffi's lawyer and close personal friend.
Bart → Daryl
Raffi's lawyer and Raffi's grade-school best friend — both inside Raffi's most trusted circle. The personal and the legal access converge in the only person who can move on the ground while remaining socially explicable as "his friend".
What Raffi disclosed to Bart in the ordinary course of a lawyer-client relationship over many years:
No other party in this case had access to all six categories of information simultaneously.
The witness to a will is a legally significant role. The witness attests that the testator (Raffi) signed in their presence and was of sound mind.
The witness on Raffi Ceylan's will is Paula Seguin — the lawyer's wife, who has been Ivana Hrvatin's best friend for 30+ years.
The witness who would later be subpoenaed to authenticate the will is the spouse of the lawyer who drafted it, and the best friend of the party whose interests the will defeats. That is not a witness. That is a participant.
Francesco Longo's voice attestation, May 25, 2026: "The snake in the grass on all of this was Bart Seguin. He knew all the things that was on Raffi's behalf. He knew the ins and outs. He knew the business, the corporation, the will, the separation agreement, the life-insurance policies. He knows it all. He knows exactly what to do to orchestrate all this for Ivana. But they needed an inside man — somebody who was best friends with Raffi. That would have been Daryl Lauzon."
One lawyer with total information. One wife as a 30-year channel. One grade-school friend on the ground. One beneficiary at the centre.
That is not a coincidence. That is the architecture.
WINDSOR POLICE SERVICE
Three officers acknowledged conflicts of interest on tape. None of them recused.
OFFICER 1
LUCY
Windsor Police Service
Acknowledged conflict of interest on the recorded line. Did not recuse. Did not refer to OPP or RCMP.
OFFICER 2
CHRIS RENAUD
Windsor Police Service
Conflict acknowledgments at timestamps [3:54], [12:20], [77:00] across one recorded call. Did not recuse.
OFFICER 3
RAY HAMLIN
Insider witness (ex-boyfriend)
Acknowledged personal ties at timestamp [06:10–07:00]. Used his network access to inform Lucy, not to formally refer the file.
CONTEXT: Lucy Ceylan reporting fraud and requesting independent investigation
"If you keep pushing this, there will be consequences."
— Constable Chris Renaud, Windsor Police Service
Criminal Code section 423 — intimidation. The speaker is a serving police officer. The recipient is a fraud complainant. The context is an active investigation request.
A police officer threatening a fraud complainant with "consequences" is itself a chargeable offence — and a perfect inversion of his statutory duty.
Each officer aware of the others' conflicts. None of them refers the file to an independent agency. None of them recuses.
This is not three separate failures of professional judgement. This is a circle.
Cross-reference: Officer Dan Call, in a separate recorded call, said: "Everything's been hidden from the courts as well. They have to hide it from the courts." — the use of "they" presupposes a coordinating group.
When Windsor Police refused to recuse or refer, Lucy filed with the Ontario Independent Police Review Director.
OIPRD agent Manuel, recorded:
"Your case is in screening. It will be 6–8 weeks."
Context: Case had already been in "screening" since July 25 — months earlier. Each call produces the same projected 6–8 weeks.
The institution tasked with policing the police has effectively run out the clock. Indefinite "screening" is the modern form of refusal.
Lucy's complaint to the Law Society of Ontario against the lawyers in the estate file was directed to Elizabeth Hall.
3.5+ months. Zero callbacks.
Voicemails left repeatedly. Each producing exactly the same response: none.
The body that licenses Ontario lawyers and is tasked with policing their professional conduct has elected, on this complaint, to do nothing — and to not even acknowledge nothing.
McTAGUE LAW FIRM · THE INSIDE COVER-UP
Three moves that prove the network protected itself first — and the client last.
SMOKING GUN #5 · THE LIE TO ANOTHER LAWYER
After Lucy retained McTague Law Firm in late 2016, partner Roger Skinner called Bart Seguin to confirm the existence of the 2011 Separation Agreement.
Bart Seguin told Skinner, on that call, that there was no Separation Agreement.
Lucy then played Skinner the November 10, 2016 recording — Bart's own voice, at minute 32:25, confirming that “in addition to shared expenses, they also had a Separation Agreement.”
Skinner “flew back with his chair” when he heard it. Then he brought in his partner David Sundin and the case kept moving.
SMOKING GUN #6 · THE COMPLAINT THAT WASN'T FILED
Despite hearing the recorded admission from Bart Seguin's own mouth and contrasting it with Bart's false statement to him by phone, Roger Skinner discouraged Lucy from filing a Law Society of Ontario complaint against Bart Seguin.
A lawyer who watches another lawyer lie about a material document — on tape — and then tells the client not to file the regulatory complaint, is not protecting the client. He is protecting the other lawyer.
SMOKING GUN #11 · THE EXEMPTION NEVER MENTIONED
Under Ontario Rule 75.1 of the Rules of Civil Procedure, estate and trust matters are EXEMPT from mandatory mediation. Betty and Lucy Ceylan could have elected not to mediate at all.
David Sundin — Lucy and Betty's own counsel — never told them about the exemption. He “highly recommended” that they mediate. He “highly recommended” the mediator (Mary Jo Nolan, the planted mediator with three undisclosed conflicts).
A lawyer who steers his client into an optional process — without ever disclosing that the process IS optional — and who hands her over to a mediator he selected and she could not have known was conflicted, is not advising her. He is funnelling her.
SMOKING GUN #3 · THE COMPUTER
In September 2016, when Julie Triferis — Raffi's girlfriend — moved out of the residence, Raffi's laptop disappeared with her departure.
On a recorded conversation, Bart Seguin admitted he took the computer. The laptop contained Raffi's personal records, his corporate correspondence, his banking records, and potentially copies of the 2011 Separation Agreement.
On a separate recording, Daryl Lozon — Raffi's long-time friend and co-owner of Northern Exposure — denied any knowledge of who took the computer. The denial is itself the corroboration: Lozon was at the house in the days after Raffi's death. If he did not see Bart take the laptop, then it was taken when Bart was alone with the property.
A lawyer who removes evidence from a decedent's residence before the estate is settled is not administering an estate. He is reaching into it.
The laptop has never been produced to the family, the court, or the Law Society. It is the missing physical exhibit that would have made many of the other smoking guns unnecessary.
EX-RAFFI-AUD-SG-007 · THE RECORDING ITSELF
Lucy Ceylan in conversation with Joel · 3 minutes 36 seconds · recorded under Criminal Code s. 184(2)(a) one-party consent · preserved in the January 2026 Master Audio Inventory as Tier 1 critical admission.
Four moves. Same direction.
Lucy and Betty Ceylan were never told the truth by anyone they paid to tell them the truth — and the people who could have told them stayed silent.
120.5 MB of legal admission across two lawyers
EX-RAFFI-AUD-001
Ray Hamlin — Career-Protection Refusal
88.4 MB · ~1.5 hours
"I'm not willing to risk my career for you" · "I went to school with Ivana" — institutional coercion + personal conflict
Listen to the recording →
EX-RAFFI-AUD-004
David Sundin — Lawyer Betrayal
32.1 MB · ~32 minutes
Switching sides admission · McTague Law Firm coordination · Mayor Dilkens connection
Listen to the recording →
EX-RAFFI-AUD-SG-008
Dana — Sundin's Assistant Admits the Irregularity
4 minutes 36 seconds · McTague Law Firm staff
“Ivana was acting as Executor without signing first” — the procedural irregularity admitted on tape by Sundin's own assistant.
Listen to the recording →
EX-RAFFI-AUD-COMPREHENSIVE-014
Joel & Brother — The 14-Minute Fraud-and-Perjury Walkthrough
14 minutes 14 seconds · two male voices (brothers) · private corroborating conversation
Comprehensive discussion of the Ivana / Bart estate-fraud architecture — analysed from outside the immediate Ceylan family. The longest single audio admission in the Master Audio Inventory.
Listen to the recording →
The regulatory-capture pattern
Lucy Ceylan has filed Law Society complaints against named Shibley Righton lawyers and connected parties since 2016.
She has produced 68+ audio confessions and admissions across all of these complaints — supplied to the Law Society of Ontario as evidence.
Number of formal complaints sustained over 10 years: 0.
A regulator that cannot police 68 recorded admissions
is not a regulator. It is the cover.
November 28, 2024 · Armin Ceylan Facebook post:
"Shibley Righton pulled the same..."
Pattern evidence from a family member. Same firm. Different case. Same outcome. Six days later, Armin Ceylan was arrested for alleged threats against Mayor Drew Dilkens — the same Mayor whose former McTague Law Firm sits in the network.
One firm at the centre.
Four lawyers in defined roles.
One Law Society witness who confirmed it.
And one recording from November 16
where a co-conspirator says it out loud.
DOWNLOAD THE CANONICAL EXHIBIT
The full canonical Exhibit 22 PDF documents the Shibley Righton LLP conspiracy node — the law firm whose founder Justice Paul R. Howard issued the 6-day Estate Certificate, whose lawyer Bart Seguin orchestrated the estate fraud, whose senior partner Brian Nolan is married to mediator Mary Jo Nolan, and whose Windsor office acts as the central hub of the network catalogued in this case file. Read the full conspiracy mapping. Pass it on.