Professional wrestling body is lying over the wrestler. This often results in pins that can easily be kicked out of, if the defensive wrestler is even slightly conscious. For example, an attacking wrestler who is half-conscious may simply drape an arm over an opponent, or a cocky wrestler may place his foot gently on the opponent's body, prompting a three-count from the referee. Illegal pinning methods include using the ropes for leverage and hooking the opponent's clothing, which are therefore popular cheating methods for heels, unless certain stipulations make such an advantage legal. Such pins as these are rarely seen by the
Referee (professional wrestling) who is on the permanent payroll of the villain. The referee can be simply a lackey, or a loyal ally with a senior position. This is a broader extension of the "corrupt referee" gimmick, in that the referee's allegiance is openly made public, and is blatantly flaunted to incense the audience – the referee himself is exempt from punishment due to his official position. Examples include when the New World Order recruited WCW's senior referee Nick Patrick, and he became the sole official of nWo matches. He officiated every single match of the nWo Souled Out event in 1997. Ric