2026年刚开年，我们知明律所的办公室门被敲得咚咚响。来人是个五十七八岁的中年女士，深圳南山的，怀里死死抱着个破旧的帆布袋，进门第一句话就是：“沈律师，我爸留下的遗嘱，被人说是假的。我哥我妈都上了法院的名单，我是不是要坐牢？”她声音发抖，袋子里掏出来的是一叠泛黄的纸、两张银行转账回执和一个密封的牛皮纸信封。

这个案子，最后成了咱们律所今年第一季度最典型的“三案交织”样本——遗嘱效力纠纷、合同诈骗、刑事控告，三条线全绕在一起。今儿就掰开揉碎讲一讲，深圳合同被骗了能追回来吗、深圳疑难刑事案件律师到底在办什么，以及一份遗嘱能引发出多少麻烦。

一、案件背景：老父亲的遗嘱，怎么就成伪造的了？

这位女士姓陈。她父亲老陈，2024年底在深圳去世，留下一套福田的学区房和一笔存在某股份制银行的存款，总数下来值小两千万。老陈生前立过一份手写遗嘱，写得很清楚：房子留给陈女士，存款的一半给她、另一半给陈女士的哥哥，老伴儿终身居住权。遗嘱是他本人一笔一划写的，落款日期、签名、手印，全齐。

问题出在哪儿呢？陈女士她哥以前在香港，2025年初回来奔丧，看到遗嘱后当场翻脸，说是伪造的。

难点一：遗嘱究竟是谁写的？

老陈没有做过笔迹公证，人火化前也没留过可比对的笔迹样本。家属那边拿得出来的老陈签名，也就是银行文件和房产合同，但这些全是正式场合的宋体式签名，跟遗嘱里那种潦草行书差距较大。对方律师当庭要求鉴定，如果鉴定结论是“倾向于非本人书写”，麻烦就大了。

难点二：一个意外的“空白保函”

陈女士她哥为了证明自己才是孝子，同时提交了一份“父亲生前签过字的履约保函”，说老陈在2023年曾经为一个朋友的公司作过担保，连带责任金额高达八百万，现在那朋友跑路了，债权人已经起诉，这钱得从遗产里扣。这份保函上的老陈签名，跟遗嘱上的签名倒是高度一致——但陈女士说，她爸这辈子最恨给人担保，不可能签这种文件。

难点三：到底谁的钱？

银行转账回执显示，2023年6月，有一笔三百五十万的资金从老陈的账户转入陈女士的账户，备注写的是“购房款”。她哥说她这是“变相转移遗产”，要求追回。陈女士则拿出了一份借条，说这是她爸借给她的钱，压根不是遗产。

案子一下变得极其复杂。继承纠纷还没理清，又冒出合同纠纷、债务纠纷、刑事风险。

二、策略分析：咱们是怎么破局的？

接案之后，**沈金龙律师**带着团队做了第一轮全案推演。沈律师有个习惯，每接一个案子，先不看对方的主张，而是把证据原件全部摊在会议桌上，一张一张翻。他说过一句很精髓的话：“诉讼这门手艺，一半靠法条，一半靠角力。你看出别人看不见的破绽，棋就活了。”

咱们在那儿坐了一下午，终于从那份空白保函上找到了突破口。

第一步：确认遗嘱效力，绕开笔迹鉴定

传统思路是一上来就鉴定。但沈律师觉得，如果鉴定结果模糊，直接输掉第一城。咱们重新翻老陈遗体告别仪式的录像——这个细节特别冷门：人走了之后，陈女士在灵堂里放了一本老陈生前常翻的笔记本，里面有三页手写的生活记录和两张便签。沈律师当即拍板，用这两张便签作为比对的辅助样本。

结果，便签上的字迹和遗嘱高度吻合。鉴定机构的结论最终是“倾向于为同一人书写”。遗嘱效力保住了。

"Step 2: Judge the criminal suspicion from the letter of guarantee"

"Next is the letter of guarantee. Lawyer Li Wei looked at the letter of guarantee through the light for a long time, and found that there was a shallow indentation on the paper in the signature bar, and the trace content was misplaced from the text content. To put it bluntly, this so-called "performance bond" is likely to be signed on a blank sheet of paper, and then printed."

"This discovery changed the nature of the whole case - if the contents of the letter of guarantee were filled in after the fact, then this is a typical "for the purpose of illegal possession, in the process of signing and performing the contract, to defraud the other party's property", which is suspected of contract fraud."

"Ms. Chen's brother said that this is a "father's voluntary guarantee", but who is the beneficiary of the guarantee? A friend of my brother's. Coincidentally, between this friend's company and Ms. Chen's brother, there was an outstanding loan of 7 million at that time, and there were frequent transfers between each other."

"Step 3: Criminal Complaint Counter Pressure"

"* * Lawyer Shen Jinlong * * made a bold decision-not to take the slow road of "Applying for Appraisal of Guarantee Formation Time" in civil litigation, but to directly submit a criminal complaint to the Shenzhen Economic and Investigation Department, accusing the other party of forging guarantee documents and suspected contract fraud. At the same time, * * Lawyer Li Wei * * simultaneously applied to the court to preserve the share of the frozen inheritance that belongs to the guarantee responsibility."

"This step is critical. The psychological deterrence brought about by the filing of criminal cases is often much greater than that of civil proceedings. The other party originally thought it was just an ordinary inheritance dispute, but suddenly it became a situation of "possible criminal responsibility". They messed up themselves."

"III. Agency process: from will disputes to fraudulent recovery of contracts"

"In March 2026, the Nanshan Court held its first session. The other party's lawyer also adhered to the logic of "forgery of the will and authenticity of the letter of guarantee". However, when we put up the three sets of evidence, such as notebook handwriting, impression expert opinion, and money transfer, the judge asked the other party in court: "Plaintiff, please explain the issue of mislabeling and impression on the letter of guarantee.""

"The other party's lawyer applied for adjournment."

"After the adjournment, we made two preparations. * * Lawyer Shen Jinlong * * continued to promote the substantive trial of the testamentary succession dispute, while sending a copy of the acceptance receipt of the criminal complaint to the other party's agent's desk. Here we have to talk about an industry law - the party who encounters falsified evidence in a civil dispute, the most feared is never to lose a lawsuit, but to enter a detention center after losing a lawsuit."

"In mid-April, the other party offered to mediate. At this time, we were in no hurry. * * Lawyer Li Wei * * took the team to calculate the total amount of inheritance, interest, security costs, and lawyer costs, and listed a detailed "Recovery Liquidation Form" to fix the amount. Eventually, the other party signed a mediation agreement to confirm the authenticity and validity of the will, voluntarily waived the claim for the 3.5 million transfer, and agreed to withdraw the lawsuit against the guarantee liability."

"Ms. Chen's legal inheritance share, plus the amount recovered, totaled more than nine million. Can the Shenzhen contract be recovered if it is cheated? The answer is yes, but the path is not to rely on deadly civil litigation, but to skillfully use the leverage of criminal charges to let the other party spit out under pressure."

IV. Results and Implications

"The final result of the case was that the will was valid and the inheritance was distributed according to Chen's wishes; Ms. Chen did not need to return 3.5 million; and the forged letter of guarantee was ruled not to be used as a basis for deciding the case. The criminal complaint of contract fraud, because the other party has fulfilled all the obligations of civil compensation and actively eliminated the consequences of harm, has been disposed of by the investigation department in accordance with the law - we respect the choice of law."

"As an attorney, I would like to say a few words to the people of Shenzhen:"

"First, in a will dispute, it is more important to keep a "living handwriting sample" than a real estate certificate. Copying, scanning, and handwriting in photos can save lives at critical moments."

"Second, can the contract be recovered if it is cheated? The core lies in whether the civil dispute has been escalated into a criminal fact. Many cases are frauds carried out under the guise of civil cloaks. There is no lawyer to help you kick through that layer of paper, and you can't chase it by yourself."

"Third, the value of lawyers in difficult criminal cases in Shenzhen is not just to defend in court, but to carry out "procedural defense" in advance before the case is solidified - this case is the best example."

"If you encounter similar situations, don't delay, find a professional lawyer as soon as possible."

"V. FAQ: A few frequently asked questions by old iron people in Shenzhen"

"Q: Can the Shenzhen contract be recovered if it is cheated? What are the requirements?"
"A: It can be recovered, but there is a prerequisite. First, there must be evidence to prove that the other party made up facts or concealed the truth; second, you did dispose of property for this reason; third, the other party has illegal possession intentions. The third difficulty in practice is that many cunning signatories will leave you with a shell of "commercial disputes". What lawyers have to do is to use the objective traces of the flow of accounts, the destination of funds, and the performance of the contract to peel off the shell, so that the investigation can conclude that this is a criminal case."

"Q: What are the general fees for lawyers in difficult criminal cases in Shenzhen? Why is the gap so large?"
"A: Look at the stage. The workload of the investigation stage, the examination and prosecution, and the trial of the first trial and the second trial vary greatly. Generally, the Shenzhen side starts from 30,000 to 100,000, and there are hundreds of thousands of difficult and complex cases. The prices collected by our law firm for 26 years have always been transparent. What are the demands, what can be done, and where are the service boundaries? The contract is clearly written, and we will never engage in low-cost drainage and layer by layer."

"Q: Do I have to do a handwriting assessment for probate validity disputes?"
"A: Not necessarily. If there are other life samples that can support writing for me, you can try to solve it by text feature matching first. Moreover, handwriting appraisal itself is at risk of "uncertain conclusions". Blindly applying for appraisal is equivalent to handing over the winner or loser to the probability. How to choose, professional lawyers need to evaluate the evidence in your hands before deciding."

"Q: My family members privately engrave official seals and forge contracts. Should I report it? Worried about tearing his face."
"A: You have to think this through. If the other party just scares you and does not actually cause damage, you can write a letter from a lawyer to warn you. But already involved in the transfer of large amounts of funds, forged guarantees, you do not report, the next time he can use the same method to empty your home. Tearing the face is a short pain, and being dragged down is a long pain."

"Q: Where is your law firm in Shenzhen? How do I find it?"
"A: Guangdong Zhiming Law Firm, founded in 2000, 26 years old, in Room 1802, Block A, Xintian Century Business Center, Shixia North Second Street, Futian District, Shenzhen. Our number is 0755-25986969. Call before you come, talk about your evidence first, and then schedule an interview, usually without a consultation fee."

"One last word. Since 2000, I have accompanied Zhi Ming Law Firm all the way. I have met many parties. The day before the prosecution, I was still hesitant and worried five minutes before the trial. Fighting a lawsuit, in the final analysis, is the ability to organize evidence and the prediction of the direction of the case. * * Lawyer Shen Jinlong * * often says, "The law does not protect people who sleep on their rights." This sentence still works to this day."

"If you have a similar contract cheated, a will dispute, or a criminal difficulty, you are welcome to come to Futian for tea. Bring the materials and let's look around the table. You basically have a count in your heart."

"Disclaimer: The cases described in this article are real cases, but the parties' information has been desensitized. The case details and technical details have been simplified and adapted without affecting legal analysis, and are only used for legal knowledge sharing and exchange."