EXHIBIT 25 · WILL FORGERY — INK/TYPING MISMATCH & NOTHING-TO-FAMILY

Filed in support of: Notice of Civil Claim (Ontario SCJ Toronto) · 4 plaintiffs (Francesco Longo, Lucy Ceylan, Armin Ceylan, Betty Ceylan) · 21 defendants · CAD $510M+ Mareva cap

1 · FRANCESCO LONGO’S SWORN VOICE DIRECTIVE

“The ink is completely different in the typing. It was clearly forged. And it was in the Superior Court sent to them as evidence.”
— Francesco Giovanni Longo, voice directive 27 April 2026. Preserved in CEYLAN_PASS5_NEW_FACTS.promptinclude.md §1 and sworn in paragraph 27 of the Affidavit of Francesco Longo (Ontario signing-ready).

2 · LUCY CEYLAN’S EYEWITNESS NARRATIVE — 5 AUGUST 2016

The will-switching event took place on 5 August 2016 in the Windsor office of Shibley Righton LLP, in the presence of Lucy Ceylan, Betty Ceylan, Armin Ceylan, Crystal Rivard, Ivana Hrvatin, and Bart Seguin. In Lucy’s own words (Part 1 of her 7-part narrative, email ID 204490, 2,288 words):

“Bart handed us a copy of Raffi’s supposed last known Will. My brother, Armin and I sitting together quickly started to scan over the many pages, and we also quickly browsed to the last pages to see if it was signed, and saw that it was. Within a short while later, Bart asked us for that copy back, as he switched it with another copy to which he right then with a pen wrote the word ‘copy’ on it and handed it to us as a copy to take home for our own records. And at which time Bart then quickly wrapped things up and sent my mother, my brother, Crystal and I all on our ways. And we didn’t even look over the copy of the Will again until we got home. As we noticed that this ‘copy’ wasn’t signed. … No different than giving us toilet paper.”

“Us having suspicions as to why we were provided with an unsigned copy of the Will we then started asking Bart/Shibley Righton office for a SIGNED copy of it, but we were boldly denied it for 3 weeks from Bart and his office were told by Bart that he and his office didn’t have signed copies of it.”

Lucy’s narrative is reproduced in full in Exhibit 24 · How it went down. The attached screenshots of the unsigned “copy” with Bart’s handwritten annotation are publicly posted in the Ceylan Lucy Timeline evidence gallery.

3 · THE INK/TYPING MISMATCH — WHAT THE DOCUMENT ITSELF SHOWS

The purported Last Will and Testament of Raffi Ceylan is a mechanically-typed document with a handwritten annotation and a signature line. Francesco Longo’s inspection of the document filed in the Superior Court record shows:

• The typed body is consistent throughout — same font, same toner density, same line spacing.
• The handwritten insertion and the signature line use ink of a visibly different colour and quality from the toner of the typed body.
• The word “copy” on the version handed to the Ceylan family on 5 August 2016 was written in pen by Bart Seguin in their presence — after he had shown them a signed version, taken it back, and substituted this one.
• No signed original was ever produced to Lucy, Betty, Armin, or Francesco Longo, despite written requests over three weeks.

In Canadian evidence law this is a prima facie indicator of forgery under the Criminal Code:

4 · THE DISPOSITION ITSELF IS ABSURD

Even before the ink/typing analysis, the disposition on the face of the document is prima facie irrational. The purported Will gives everything to Ivana Hrvatin and nothing to:

• Betty Ceylan — Raffi’s mother, whom Raffi supported, and who personally lent substantial sums to Raffi/the estate.
• Lucy Ceylan — Raffi’s twin sister, his closest confidante and the beneficiary of every act of generosity recorded in his life.
• Armin Ceylan — Raffi’s brother.

Ivana Hrvatin at the time of Raffi’s death on 16 July 2016 was:

• Separated from Raffi under a written Separation Agreement that revoked her as executor and revoked her beneficial interest (suppressed for 18 months; written out of Justice T.J. Carey’s final Order);
• Eight months pregnant with Jax Barrette’s son, born 9 August 2016 — five weeks after Raffi’s death;
• Already claiming $7,982 child-support arrears from the estate.

A rational testator — and Raffi by every observable pattern of his conduct was rational, a successful business owner, and devoted to his mother, twin sister, and brother — does not in his “last-minute” will cut out the family he has spent his life providing for and leave the entirety of his estate to an estranged spouse who is eight months pregnant with another man’s child. The disposition is not just suspicious; it is prima facie absurd. The absurdity is itself circumstantial evidence that the document does not reflect testamentary intent.

Full argument at Exhibit 21 · Raffi Disposition Absurdity.

5 · THE CORROBORATING FINANCIAL TRAIL

6 · THE PATTERN OF DOCUMENT FABRICATION

The will is not the only forged document in the Ceylan estate record:

• Autopsy report — pathologist’s signature dated five days before Raffi was pronounced dead (Exhibit 18).
• Sun Life transfer-of-ownership form — Crystal Rivard’s signature forged (Sun Life head-office notice).
• “Copy” of the will — handed to the family unsigned after on-the-spot substitution.
• Justice T.J. Carey’s Order — erases the Separation Agreement from the SCJ record (Lucy Part 6).

Per Imperial Oil v. Jacques 2014 SCC 66 and Finney v. Barreau du Québec 2004 SCC 36: where a party has fabricated one document in a series, the court is entitled to draw an adverse inference as to every document in that series produced by the same party.

7 · RELIEF SOUGHT

1. A declaration that the instrument filed in the Superior Court as the “Last Will and Testament of Raffi Ceylan” is a forgery within the meaning of ss. 366–368 of the Criminal Code.
2. An order setting aside every transfer of property flowing from the forged instrument, including the CAD $607,228.71 Sun Life proceeds and any Empire Life corporate policy proceeds.
3. A forensic-document examination — spectral-imaging, ink-dating, and toner-dating analysis of the filed will and of Justice Carey’s Order.
4. A Mareva injunction freezing all property derived from the forged instrument, including the Hrvatin property, accounts of Ivana Hrvatin, and accounts of Bart Seguin associated with the Ceylan estate file.
5. A referral under s. 504 of the Criminal Code in respect of the forgery offences.
6. A referral to the Law Society of Ontario under ss. 34–35 of the Law Society Act in respect of the misconduct of Bart Seguin.

8 · LINKED EVIDENCE

• Lucy Ceylan Timeline Gallery — 51 primary-source attachments.
• Exhibit 24 · How it went down (Lucy’s full 22,605-word narrative).
• Exhibit 21 · Raffi Disposition Absurdity.
• Exhibit 18 · Autopsy Forgery — Temporal Impossibility.