The Four Smoking Guns
The autopsy was signed five days BEFORE he died
Dr. Queen's signature on the autopsy report bears a date five days prior to Raffi Ceylan's pronounced date of death. A pathologist cannot autopsy a living man. This is forgery on the face of the document.
Read Exhibit 18 →Bart Segan · 16 November 2016
On tape, the lawyer for the estate admits facts that were only knowable through direct communication with the beneficiary, Ivana Hrvatin. Bart Segan's wife is Ivana Hrvatin's best friend. The conflict of interest bridges the enterprise.
Read Exhibit 19 →Dan Potvin · Windsor Police Service
A seventy-minute recorded call with WPS Detective Dan Potvin contains a three-investigator admission of awareness. The recording is in the possession of Lucy Ceylan, who holds more than three hundred audio recordings of the investigation.
Read Exhibit 20 →The second insurance policy nobody opened
Separate from Sun Life, an Empire Life corporate policy existed under Raffi Ceylan's authority. It has never been opened, never been paid out under anyone's verified direction, and never been acknowledged in the Sun Life beneficiary transfer. The Norwich Pharmacal Order sought in this matter targets full disclosure.
Read Exhibit 22 →The Five Plaintiffs · Windsor Justice Trifecta + Ceylan Family
| Role | Name | Chapter · contribution to the unified claim |
|---|---|---|
| Principal Claimant #1 (Trifecta · lead · self-represented) | Francesco Giovanni Longo | Italian-Canadian Windsor claimant · 21 years of transnational persecution · brings the unified Windsor-cartel matter · lead on Chapter 1 |
| Principal Claimant #2 (Trifecta · by estate) | Estate of Raffi Ceylan | Deceased 16 July 2016, Chapleau, ON · autopsy forgery temporally impossible · CAD $600K+ Sun Life fraudulent transfer · Chapter 2 |
| Principal Claimant #3 (Trifecta · living) | David Simetic | Estate of Ivan Valentich matter · 328-page investigation binder · Jerry L. Goldberg audio admission of forging bank statements · CAD $400,000+ stolen · CAD $60M claim · Chapter 3 |
| Co-claimant · Ceylan family | Lucy Ceylan | Twin sister of Raffi · principal witness · holder of 300+ audio recordings |
| Co-claimant · Ceylan family | Armin Ceylan | Brother of Raffi · currently detained in Ontario |
| Co-claimant · Ceylan family | Betty Ceylan | Mother of Raffi · personally paid CAD $30,000 out of pocket for inquiries institutional channels refused to fund |
The Twenty-Four Defendants (Pass 6 Addendum)
- 1. Ivana Hrvatin · Sun Life beneficiary · CAD $600K+ received 19 Sept 2016
- 2. Sun Life Assurance Company of Canada
- 3. Empire Life Financial Corporation
- 4. Bart Segan (also appearing as Seguin) · counsel · Ceylan matter
- 5. Paula Segan · spouse of #4 · best friend of #1
- 6. David Sundin · counsel of record · Ceylan matter
- 7. Shibley Righton LLP · institutional legal infrastructure
- 8. Windsor Police Service
- 9. Sgt. Chris Renaud · WPS Fraud
- 10. Det. Dan Potvin · WPS
- 11. Drew Dilkens · Mayor of Windsor · Chair WPSB
- 12. Jason Bellaire · retired Chief WPS
- 13. Jason Crowley · successor Chief WPS
- 14. Eddie Francis · predecessor Mayor
- 15. Justice John Paul Howard · stamped file 2016–2017
- 16. Mary Jo Nolan · conflicted mediator · Ceylan matter
- 17. Windsor Police Services Board (institutional)
- 18. Dr. Queen · pathologist on forged Raffi autopsy
- 19. Ontario Centre for Forensic Sciences (institutional)
- 20. Additional coroner-office respondents per Filing #01A
- 21. 🌉 Dr. Emily Groot · Ontario Chief Coroner 2016 · Raffi Ceylan cover-up (no strychnine test, unsigned death certificate discrepancy, 3 recorded calls with Lucy Ceylan) · family bridge to #22
- 22. 🌉 Norman Groot · 1999 obstruction-of-justice conviction as Peel Regional Police officer (R. v. Groot) · family bridge to #21 · Simetic matter perpetrator
- 23. 🌉 Jerry L. Goldberg · lawyer · audio admission of forging bank statements · Estate of Ivan Valentich · CAD $400K+ stolen (Simetic matter)
- 24. 🌉 Warren Fullerton · Mareva target · Simetic matter
🌉 Defendants #21–#24 added in Pass 6 Addendum (27 April 2026) on voice authorization of Francesco Giovanni Longo correcting Pass 5 and pleading the Simetic chapter into the unified claim. The Groot family entries establish the cross-chapter RICO bridge (s. 467.1 CCC).
Phase-by-Phase Recovery Timeline (Filing #23)
All 22 Exhibits · Direct Links
| # | Exhibit | |
|---|---|---|
| 14 | Platform Censorship · GitHub Suppression | |
| 15 | Empire Life Hidden Policy (Pass 4) | |
| 16 | Coroner Spinal Cord Omission | |
| 17 | Aggravated Damages Multiplier Schedule | |
| 18 🎯 | Autopsy Forgery · Temporal Impossibility | |
| 19 🎯 | Bart Segan Nov 16 2016 Taped Admission + Paula/Ivana Bridge | |
| 20 🎯 | Dan Potvin 70-Minute Recorded Police Confession | |
| 21 | Raffi Ceylan Testamentary Absurdity | |
| 22 🎯 | Empire Life CAD $10M+ Corporate Policy |
Core Pleadings
| # | Filing | |
|---|---|---|
| 01 | Notice of Civil Claim | |
| 01A | NOCC Pass 5 Addendum (+4 defendants, Empire Life, $510M cap) | |
| 01B | Venue Pivot — Ontario SCJ Toronto | |
| 02 | Information under CCC s.504 (15 counts) | |
| 03 | Mareva Injunction Application | |
| 04 | Norwich Pharmacal Application | |
| 05A | Francesco Longo Affidavit · Ontario signing-ready | |
| 06 | Lucy Ceylan Affidavit | |
| 07 | Armin Ceylan Affidavit | |
| 08 | Betty Ceylan Affidavit | |
| 09 | Draft Mareva Order | |
| 10 | Draft Norwich Pharmacal Order | |
| 11 | Service Plan | |
| 12 | Viva Voce Protocol Memo | |
| 13 | Unified Tort Filing Memo | |
| ⚡ 23 | Interim Relief Motion · Phase-by-Phase Recovery |
Legal Foundation (selected authorities)
- Aetna Financial Services Ltd. v. Feigelman, [1985] 1 S.C.R. 2 — Mareva jurisdiction
- Norwich Pharmacal Co. v. Customs and Excise Commissioners, [1974] AC 133 (HL) — Norwich Order
- GEA Group AG v. Ventra Group Co., 2009 ONCA 619 — Canadian Norwich application
- Pettkus v. Becker, [1980] 2 S.C.R. 834 · Soulos v. Korkontzilas, [1997] 2 S.C.R. 217 — constructive trust and tracing
- British Columbia (Minister of Forests) v. Okanagan Indian Band, 2003 SCC 71 — interim funding for indigent claimants
- Lazarus Estates Ltd. v. Beasley, [1956] 1 Q.B. 702 (CA), cited Hryniak v. Mauldin, 2014 SCC 7 — fraud unravels all
- R. v. Trochym, 2007 SCC 6 — treatment of temporal-impossibility evidence
- R. v. Babos, 2014 SCC 16 — abuse of process / shocks the conscience
- Vancouver (City) v. Ward, 2010 SCC 27 — Charter damages
- Coroners Act, R.S.O. 1990, c. C.37, s. 15 — exhumation jurisdiction
Evidence · Embedded on the Public Record
Standing exhibit library for the Estate of Raffi Ceylan. Every item below is loaded directly on this page so that any visitor — judge, journalist, whistleblower, Law Society investigator, RCMP, or member of the public — can view the primary-source material without going through another door. No authentication, no download, no clicks; it sits here, in daylight.
🎥 Audio on the public record
Discussion of the events of Raffi’s passing and the concealment machinery. This is the conversation from which Lucy’s seven-part written timeline (Exhibit 24) was drawn. Posted for transparency.
Direct download · MP3 · 95 MB
📷 Lucy Ceylan Primary-Source Evidence Gallery · 51 attachments
These are the images Lucy attached in sequence with her seven-part narrative. Will-switching evidence, TD deposit slip, Sun Life forgery notice, Justice Carey Order, Sundin email threads, FMSA, text messages — the primary sources, as received. Click any thumbnail for the full-resolution original. Open the full gallery →
📄 The Central Smoking-Gun Exhibits
Ink of handwritten portion visibly different from typed body. Will gives everything to Ivana Hrvatin — nothing to mother, twin sister, brother. <strong>The central smoking gun.</strong>
Open exhibit →
Pathologist’s signature dated five days before Raffi was pronounced dead. Temporal impossibility.
Open exhibit → · PDF
Bart Seguin on tape 16 Nov 2016 telling Betty and Crystal “no cheque has gone to her in her name” — while the Sun Life notice of Ivana’s receipt sits in his file folder.
Open exhibit →
70-min recorded Windsor Police admission by Dan Potvin that Armin Ceylan was arrested by accident on Ivana’s word.
Open exhibit →
A rational testator does not cut out his mother, twin sister, and brother to leave everything to an estranged wife who is 8 months pregnant with another man’s child. Absurdity as evidence of fabrication.
Open exhibit →
Unopened Empire Life corporate policy estimated CAD $10M+ that only Raffi had authority over. Second financial pipe never explored by any prior counsel.
Open exhibit →
Lucy Ceylan’s seven-part written timeline, verbatim from 8 Feb 2026 emails. The spine of the case.
Open exhibit → · PDF
Coroner’s failure to perform the spinal-cord test that at Raffi’s age would have confirmed or excluded poisoning. Vomitus present at scene, never tested.
Open exhibit →
⚛️ Corroborating narrative documents
- How it went down — memorial landing page
- Ontario SCJ Toronto filing package · 25 filings · 22 exhibits
- Filing 01 · Notice of Civil Claim (amended for Ontario SCJ Toronto)
- Filing 01A · Pass 5 Addendum
- Filing 03 · Mareva Injunction Application
- Filing 06 · Affidavit of Lucy Ceylan
- Filing 07 · Affidavit of Armin Ceylan
- Filing 08 · Affidavit of Betty Ceylan
For the unified case view (Francesco Longo + Estate of Raffi + David Simetic) see David Simetic · Windsor Justice Trifecta.
How to Contact / Verify
Francesco Giovanni Longo is self-represented and indigent. Primary email of record: flongo11@gmail.com. Physical materials and service copies are held at the Windsor, Ontario address filed with the Ontario SCJ Toronto Registry.
All affidavits identified above as “sign or viva voce” are ready for signature by the respective Ceylan plaintiff. Francesco's Affidavit (Filing #05A) is signing-ready today.