Statement of Claim

Combined pleading unifying the 2021 Windsor unlawful-arrest matter and the Ceylan trifecta · Cross-institutional civil conspiracy · Filed 27 April 2026 · FILING-GRADE

BETWEEN:

FRANCESCO GIOVANNI LONGO, of the City of Windsor, in the Province of Ontario, in his personal capacity; and

LUCY CEYLAN, ARMIN CEYLAN, and BETTY CEYLAN, of the Province of Ontario (Ceylan co-plaintiffs on the Raffi Ceylan arc);

all self-represented, with Mr. Longo serving as litigation agent pursuant to Federal Courts Rules 120 and 121,

Plaintiffs

— and —

HIS MAJESTY THE KING IN RIGHT OF CANADA (Crown Liability and Proceedings Act, RSC 1985, c. C-50, s. 3), represented by the Attorney General of Canada; and the additional Defendants set out in Schedule A attached (federal, provincial, municipal, professional, corporate, and individual),

Defendants

Jurisdiction. This Court has native jurisdiction over this action pursuant to: Federal Courts Act, RSC 1985, c. F-7, ss. 17, 23, and 25 (claims against the Crown; Canadian maritime-like jurisdictional sweep for federal undertakings; and VCCR-Article-36 / consular-notification claims touching federal officials); Crown Liability and Proceedings Act, RSC 1985, c. C-50, s. 3; Canadian Charter of Rights and Freedoms, s. 24(1); Canadian Bill of Rights, s. 2(e); Vienna Convention on Consular Relations, Article 36, as ratified domestically by the Foreign Missions and International Organizations Act, SC 1991, c. 41. Joinder of the 2021 Windsor branch and the Ceylan trifecta branch is proper under Rules 102 and 104 on the basis of a common question of law and fact — retroactive document creation by public officials across multiple institutions coordinating under a single operational design.

Part I · Nature of the Action

This is a consolidated civil action in malicious prosecution, misfeasance in public office, negligent investigation, civil conspiracy, breach of fiduciary duty, fraud, forgery, conversion, and breach of Charter rights, arising from a continuous transnational operation targeting the Plaintiff Francesco Giovanni Longo and, by extension, the Ceylan family.

The action has two arcs: (a) the 2021 Windsor arc — file #21-845 (Zvaniga) prosecuted by Windsor Police Service and the Ontario Ministry of the Attorney General through to dismissal on 15 September 2025, with eight independent evidence-tampering smoking guns detailed below; and (b) the Ceylan trifecta arc — the 2016 death of Raffi Ceylan with pre-dated autopsy, the CAD $600,000+ Sun Life fraudulent beneficiary transfer and parallel Empire Life hidden policy, and the continuing arbitrary detention of Armin Ceylan.

The two arcs are not separate. They share the identical operational fingerprint: retroactive document creation. The charge in 21-845 was created after the arrest; the autopsy in Raffi Ceylan's death was signed before the death; the purported will in the Ceylan estate was typed after any possible testamentary intent; and the extradition Information in the 2005 U.S. matter (pleaded in the companion MDFL Coram Nobis v4) was signed before any underlying charge existed. The same technique, in the same province, over a span of 21 years, against the same Plaintiff family — is not coincidence. It is a signature.

Part II · Keystone Count — Shared-Technique Civil Conspiracy

Each Defendant who affixed, authorised, relied upon, or concealed the existence of a retroactively-created public document — in any of the four episodes listed in paragraph 3 — did so as part of a continuing unlawful-means civil conspiracy within the meaning of Canada Cement LaFarge Ltd. v. British Columbia Lightweight Aggregate Ltd., [1983] 1 SCR 452, and Hunt v. TD Securities, 2003 CanLII 3649 (ONCA).

The conspiracy has two branches: the predominant-purpose branch (to cause economic and liberty harm to the Plaintiffs) and the unlawful-means branch (forgery, obstruction, perjury, breach of trust, criminal conspiracy). Both branches are pleaded in the alternative; the Plaintiffs are entitled to elect on the evidence.

The shared-technique count is the evidentiary keystone tying every defendant across every institution into a single pleaded civil wrong that this Court cannot sever without hearing the whole.

Part III · The 2021 Windsor Arc — Eight Smoking Guns

The Windsor Police Service arrested the Plaintiff Longo on 6 May 2021 on charge of mischief over $5,000 contrary to Criminal Code s. 430(1)(a) under file #21-845, Occurrence #21-38605, lead officer PC Phillip Gratton #19407. The Ontario Ministry of the Attorney General (Windsor Crown's office) prosecuted the file through to 15 September 2025 before Justice Bazylko of the Ontario Court of Justice.

The Plaintiff pleads and relies upon eight independently-sufficient evidentiary anomalies, each documented in Research Exhibit R-8 and incorporated into this pleading by reference:

SG	Smoking Gun	Legal Ground
1	Physically-impossible 1-minute booking (18:15 → 18:16) on 6 May 2021	Fabricated police record; R. v. Harrison 2009 SCC 34; Stinchcombe
2	47-minute surveillance gap with motion-activated cameras silent during the period of alleged mischief	Prima facie exculpatory; R. v. La 1997 SCC 680 — duty to preserve
3	14-month video-evidence upload delay (8 videos uploaded 6 July 2022 of 6 May 2021 arrest)	Direct Stinchcombe 1991 SCC 326 breach
4	25+ months of prosecution without ever requesting damages proof — Zvaniga's own 13 June 2023 email admission	Malicious prosecution; Nelles v. Ontario [1989] 2 SCR 170; Miazga v. Kvello 2009 SCC 51
5	Teknickal Konstrux estimate dated 16 May 2021 (10 days after incident), expired after 30 days, self-disclaimed as hypothetical; actual plumber invoice was $300 (94% below $5,000 threshold)	Element of offence not made out; negligent investigation; Hill v. Hamilton-Wentworth 2007 SCC 41
6	Two inconsistent disclosure versions with reordered documents	Continuity-of-disclosure violation; abuse of process
7	15 September 2025 — 79 files bulk-uploaded at approximately 22:00 the same night Bazylko J. dismissed the case without hearing any of the Plaintiff's 17 constitutional motions	Denial of audi alteram partem; Charter ss. 7, 11(d); R. v. Babos 2014 SCC 16
8	Justice Bazylko's structural conflict of interest (former 14-year Crown Attorney 2009–2023 adjudicating Crown misconduct motions)	Reasonable apprehension of bias; Committee for Justice and Liberty v. NEB [1978] 1 SCR 369; Wewaykum 2003 SCC 45

The Plaintiff pleads that the combination of the 1-minute booking, the 47-minute gap, the 14-month video delay, the 25-month damages gap, and the pre-dated estimate proves charge fabrication — the charge was not based on evidence; evidence was (incompetently) reverse-engineered onto a charge already laid. This is the retroactive-document-creation technique in the Windsor branch.

Part IV · The Ceylan Trifecta Arc

The Ceylan arc pleads and relies upon the full content of the Ontario SCJ Toronto filing package (all 23 filings and 22 exhibits) mirrored at canadianpeoplestrust.com/ceylan_bcsc, incorporated herein by reference. The salient retroactive-document elements are:

Autopsy signed before death. Dr. Queen signed Raffi Ceylan's autopsy report on 11 July 2016 — five days before Mr. Ceylan's death on 16 July 2016. A document purporting to record the results of a post-mortem examination cannot lawfully be signed before the decedent has died. This pleads forgery (CCC s.366), uttering forged document (CCC s.368), fraud over $5,000 (CCC s.380 — the Sun Life CAD $600,000+ payout and parallel Empire Life policy), breach of trust by public officer (CCC s.122), and professional misconduct under the Regulated Health Professions Act (Ontario). See companion filing CPSO Disciplinary Complaint.

Will typed after intent. The purported will of Raffi Ceylan in the Ontario SCJ estate matter exhibits an ink-versus-typing mismatch (see Ceylan Exhibit 18 · WILL_FORGERY_INK_TYPING_MISMATCH) and produces a disposition — everything to divorced former spouse Ivana Hrvatin, nothing to twin sister Lucy, brother Armin, or mother Betty — that is facially inconsistent with every observable pattern of Raffi Ceylan's lifetime conduct. The purported testamentary instrument is pleaded as fabricated.

Sun Life + Empire Life. The CAD $600,000+ Sun Life life-insurance payout to Ivana Hrvatin (defendant) was engineered through a beneficiary-change process that the Plaintiffs plead was fraudulent. A separate Empire Life corporate policy (CAD $10M+ face), never disclosed in the estate proceedings, has surfaced — Raffi Ceylan was the sole authorised person. The autopsy forgery is foundational to any claim under either policy.

Bart Seg(a/u)in knowledge bridge. Defendant Bart Seguin (acting in the estate matter) is married to a person who was best friends with Ivana Hrvatin — the knowledge-and-motive bridge explaining how Seguin possessed the intimate financial and separation-agreement details necessary to advance the fraudulent transfer. This pleads civil conspiracy (CCC s.465), conflict of interest (Law Society Rule 3.4), and joint-enterprise liability.

Armin Ceylan's ongoing detention. Armin Ceylan's continuing detention in Ontario correctional custody is without lawful basis disclosed to the family. The Plaintiffs plead unlawful confinement (CCC s.279) and Charter s. 9 (arbitrary detention) alongside habeas corpus relief pursuant to s. 10(c).

Part V · Transnational Context — the 2005 Predicate

The Plaintiffs plead the 2005 DEA-orchestrated cross-border rendition of Francesco Longo as factual predicate and evidence of pattern. The full U.S. dimension is the subject of the companion MDFL Coram Nobis Petition v4. Canadian liability attaches for Canadian participation in that operation — including RCMP, Justice Canada extradition officials, the LAO certificate irregularity, and defence counsel Gibson/Ducharme complicity — pleaded in Schedule A Parts III–V.

Part VI · Causes of Action

Malicious prosecution per Nelles v. Ontario, Miazga v. Kvello Estate 2009 SCC 51 — against the Ontario MAG and Crown attorneys in 21-845.
Negligent investigation per Hill v. Hamilton-Wentworth 2007 SCC 41 — against WPS and PC Gratton #19407.
Misfeasance in public office per Odhavji Estate v. Woodhouse 2003 SCC 69 — against every named public-officer Defendant.
Breach of fiduciary duty — against Bart Seguin, Sun Life, Empire Life, and the Ontario Superior Court of Justice estate-process actors.
Civil conspiracy (two branches) per Canada Cement LaFarge — the keystone count at Part II above.
Fraud, forgery, and uttering forged document per R. v. Zlatic [1993] 2 SCR 29; CCC ss. 366, 368, 380 — against autopsy signatories, will drafters, and Sun Life beneficiary-change processors.
Conversion — against Ivana Hrvatin and downstream recipients of Sun Life / Empire Life proceeds.
Unjust enrichment per Garland v. Consumers' Gas 2004 SCC 25.
Breach of Charter ss. 7, 8, 9, 10(b), 11(b), 11(d), 11(h), 12, 15, 24(1) — against Crown Defendants.
Intentional infliction of emotional distress — against all Defendants on both arcs.
Violation of Vienna Convention on Consular Relations Article 36 (as predicate) — incorporated by reference from the MDFL Coram Nobis Petition v4.

Part VII · Relief Sought

The Plaintiffs claim:

General, special, aggravated, and exemplary damages in an amount to be proven at trial, not less than CAD $510,000,000 (the Mareva-anchor quantum pleaded in the Ceylan filing package, compounded across the Windsor arc per Schedule B).
Mareva injunction against all Defendants with proprietary interests in Sun Life / Empire Life / Ceylan estate assets, as pleaded in Ceylan filings 03 and 09.
Norwich Pharmacal orders against GitHub Inc., Sun Life Financial, Empire Life Insurance, Cloudflare Inc., and the Ontario MAG digital disclosure portal administrators.
Declaratory relief that (a) the 15 September 2025 dismissal order in 21-845 is void for structural bias and denial of audi alteram partem; (b) the Raffi Ceylan autopsy of record is a forged instrument; (c) the Sun Life beneficiary change of record was procured by fraud; and (d) the Plaintiff Longo's 2005 U.S. conviction rests on Canadian participation in a VCCR-Article-36 violation.
Charter damages per Vancouver (City) v. Ward 2010 SCC 27.
Habeas corpus relief for Armin Ceylan.
Referral to the Royal Canadian Mounted Police and the Ontario Provincial Police for criminal investigation of CCC ss. 122, 137, 139, 341, 366, 368, 380, 423.1, 465.
Referral to the Canadian Judicial Council in respect of Justice Bazylko.
Referral to the Law Society of Ontario in respect of Ashley Dale, Laura Joy, Kristine Krainz, Bart Seguin, and any counsel of record identified in Schedule A.
Costs on a full-indemnity basis.
Such further and other relief as this Honourable Court deems just.

Part VIII · Cross-Referenced Filings and Schedules

Doc	Description	Location
Schedule A	Full list of Defendants across all seven implicated institutions	SCHEDULE_A_RESPONDENTS.md
Schedule B	Damages schedule — Windsor arc + Ceylan arc + 2005 predicate	EXHIBIT_10_DAMAGES_SCHEDULE_MASTER.md
Ceylan Package	23 filings + 22 exhibits, HTML+PDF, 4 plaintiffs, 21 defendants, CAD $510M Mareva	/ceylan_bcsc/
R-1 through R-8	Research cluster — deep-dive amplifications, 27,000+ words	/research/
CPSO Complaint	Professional-discipline complaint re pre-dated autopsy	CPSO Complaint
Italian Denuncia	Dual-language criminal complaint under Italian Codice Penale arts. 110, 323, 368, 479, 605, 610, 615-bis, 617-quater, 416	Denuncia-Querela
MDFL Coram Nobis v4	U.S. dimension — 2005 VCCR-Art-36 violation, extradition forgery, fabricated appeal	Coram Nobis v4
Audio Admissions	11 recorded institutional admissions mirrored on canonical domain	/audio/admissions/

Part IX · Verification

The facts pleaded in this Statement of Claim are true to the knowledge of the Plaintiff Francesco Giovanni Longo based on his direct observation, participation, and documentary custody; and true to his information and belief as to the Ceylan-family facts, which information and belief derive from the verbatim 22,605-word timeline provided by Lucy Ceylan in February 2026 (Ceylan Exhibit 24) and the corroborating documentary record.

Dated at Windsor, Ontario, this 27th day of April, 2026.

___________________________________
FRANCESCO GIOVANNI LONGO
Plaintiff, self-represented, litigation agent for Lucy Ceylan, Armin Ceylan, and Betty Ceylan
Email: flongo11@gmail.com · Address for service: canonical email above plus canadianpeoplestrust.com

TO: The Administrator, Federal Court of Canada, Toronto Local Office
AND TO: The Attorney General of Canada, Department of Justice, Ottawa
AND TO: The Defendants set out in Schedule A

Canonical URL: canadianpeoplestrust.com/filings/COMBINED_FEDERAL_COURT_STATEMENT_OF_CLAIM