College of Physicians and Surgeons of Ontario · Formal Complaint
CPSO Disciplinary Complaint — Autopsy Signed Before Death
Subject physicians: Dr. Queen · Dr. Bishwajit · Dr. Cameron · Decedent: Raffi Ceylan (DOD 16 July 2016, Chapleau, Ontario) · Filed: 27 April 2026 · Complainant: Francesco Giovanni Longo on behalf of Betty Ceylan, Lucy Ceylan, and Armin Ceylan
TO: College of Physicians and Surgeons of Ontario
80 College Street · Toronto, Ontario · M5G 2E2
investigations@cpso.on.ca · Intake: 1-800-268-7096
VIA: Formal complaint pursuant to Regulated Health Professions Act, 1991 (Ontario) Schedule 2, s.25; Medicine Act, 1991; and CPSO Complaints Protocol
Part I · Statement of Complaint
The complainants, by these presents, lodge formal professional-discipline complaints against three physicians of record for conduct amounting to disgraceful, dishonourable, or unprofessional conduct within the meaning of s.51(1)(c) of the Health Professions Procedural Code (Schedule 2 to the Regulated Health Professions Act), on the grounds set out below.
Executive Summary. The autopsy report for Raffi Ceylan bears a physician's signature dated five (5) days before Mr. Ceylan's death. This is temporally impossible. It is direct documentary evidence of fabrication of a medical record in a death investigation, within the meaning of CCC s.366 (forgery), s.368 (uttering forged document), and s.380 (fraud over $5,000, where insurance proceeds exceed that threshold). The CPSO has mandatory statutory authority to investigate and suspend the licences of the physicians of record.
Part II · The Temporally Impossible Signature
Undisputed Facts
- Raffi Ceylan died: 16 July 2016, Island Lake Road, Chapleau, Ontario (coroner file of record).
- Autopsy signature date: 11 July 2016 (five days before death).
- Physician of record on signature: Dr. Queen.
- Supervising / reviewing physicians of record: Dr. Bishwajit and Dr. Cameron.
- Source: Original coroner-system autopsy report preserved in the Canadian People's Trust evidence hub as Exhibit 18 (
RAFFI_CEYLAN_AUTOPSY_FORGERY_EXHIBIT) and within the Ontario Superior Court of Justice record in the Ceylan estate proceedings.
An autopsy is, by definition, a post-mortem examination. A post-mortem examination signed before death is not an autopsy — it is a fabricated document. There is no professional, clinical, or administrative circumstance in which a physician may lawfully affix a completed autopsy signature to a report on a patient who has not yet died.
Part III · Regulatory Breaches Alleged
| Provision | Breach |
|---|
| Medicine Act, O. Reg. 856/93, s.1(1)14 — "Falsifying a record relating to the member's practice" | Autopsy report signed before the event it purports to document |
| Medicine Act, O. Reg. 856/93, s.1(1)33 — "Engaging in conduct... that would reasonably be regarded by members as disgraceful, dishonourable or unprofessional" | Complete dereliction of forensic duty in a death investigation |
| Coroners Act, R.S.O. 1990, c. C.37, s.28 — duty to accurately report cause of death | Report cannot accurately describe a death that had not yet occurred |
| Vital Statistics Act, R.S.O. 1990, c. V.4, s.21 — duty of truthful medical certification of death | Pre-dated certification is untruthful on its face |
| CPSO Policy 4-12 — Medical Records Documentation | Signature without contemporaneous clinical event |
| CPSO Policy 8-07 — Third Party Reports | Report prepared for coroner/insurer without fact basis |
Part IV · Criminal Code Overlay
The same conduct that breaches the professional standard also engages the following Criminal Code provisions:
- s.366 — Forgery: making a false document knowing it to be false with intent that it be acted upon as genuine.
- s.368 — Uttering forged document: transmitting the report to the Office of the Chief Coroner, insurance carriers (Sun Life; Empire Life), and downstream estate proceedings.
- s.380 — Fraud over $5,000: the autopsy record underlaid the Sun Life transfer of CAD $600,000+ and triggered the (previously undisclosed) Empire Life policy — both exceed the statutory threshold many times over.
- s.139 — Obstruction of Justice: the fabricated medical record obstructed the lawful administration of the estate, the coroner's investigation, and the civil matter that followed.
- s.465(1)(c) — Conspiracy: where multiple physicians and downstream actors coordinated.
The CPSO is empowered to make referrals to law enforcement under s.36 of the Regulated Health Professions Act.
Part V · Aggravating Context
- Spinal-cord forensic test omitted. The Coroner's Office failed to conduct the spinal-cord toxicology test that would have confirmed or excluded poisoning at Raffi Ceylan's age. Omission of a standard-of-care test, combined with a pre-dated signature, moves this beyond error into indicium of coverup.
- Sun Life CAD $600,000+ fraudulent beneficiary change. The autopsy record was relied upon in the Sun Life payout to Ivana Hrvatin, whose relationship with the decedent had been terminated by divorce.
- Empire Life hidden policy. A separate undisclosed Empire Life corporate policy (CAD $10M+) has surfaced in the estate record — the autopsy report is foundational to any claim under that policy as well.
- Pattern with Canadian institutional forgery. The Raffi Ceylan autopsy sits inside a broader documented pattern — see R-8 (Zvaniga 21-845), R-4 (Windsor Police Pattern-of-Conduct), and the Ceylan Federal Court filing package.
Part VI · Relief Sought
- Immediate interim suspension of the licences of Dr. Queen, Dr. Bishwajit, and Dr. Cameron pending investigation, pursuant to s.25(4) of the Health Professions Procedural Code.
- Formal Inquiries, Complaints and Reports Committee (ICRC) investigation of each named physician.
- Referral of the autopsy report for independent forensic document examination (ink-and-paper analysis, signature provenance, metadata inspection of any electronic version).
- Audit of all autopsies signed by Dr. Queen between 2014 and 2018 for similar temporal irregularities.
- Referral to Ontario Provincial Police for investigation of CCC ss. 137, 139, 366, 368, 380, 465(1)(c).
- Referral to the Office of the Chief Coroner for Ontario under the Coroners Act to re-open the Raffi Ceylan death investigation with the spinal-cord toxicology test that was omitted.
- Restitution of all autopsy fees paid from public funds for the invalid report.
Part VII · Evidentiary Annexes
| Annex | Description | Location |
|---|
| A-1 | Autopsy report with pre-dated signature | Ceylan filing package Exhibit 18 · Ontario SCJ estate record |
| A-2 | Raffi Ceylan death certificate (16 July 2016) | ServiceOntario vital records; Ceylan family custody |
| A-3 | Sun Life beneficiary change and payout records | Ceylan filing package Mareva motion materials |
| A-4 | Empire Life policy discovery | Exhibit 22 · Ceylan filing package |
| A-5 | Ontario SCJ Ceylan estate file materials | Windsor SCJ court record (Justice John Paul Howard) |
| A-6 | Lucy Ceylan verbatim timeline (22,605 words, February 2026 emails) | Exhibit 24 · canonical at 24_EXHIBIT_HOW_IT_WENT_DOWN_LUCY_TIMELINE.html |
Part VIII · Complainant Particulars and Standing
The named complainant, Francesco Giovanni Longo (DOB 24 April 1972, resident of Windsor, Ontario), files on his own behalf and as designated agent of the Ceylan family (Betty Ceylan, Lucy Ceylan, Armin Ceylan). Standing derives from:
- Direct witness standing under Regulated Health Professions Act s.25(2) — any member of the public may file.
- Ceylan family designation as complainants-of-record (Exhibit 24 verbatim timeline).
- Public interest standing under Downtown Eastside Sex Workers United Against Violence v. Canada 2012 SCC 45.