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) Flair and The Four Horsemen had their own personal referee in WCW, Charles Robinson, who eventually adopted the look and mannerisms of Flair, and earned the nickname "Little Naitch", from Flair's nickname "Nature Boy". For a time in WCW, referees would not work Scott Steiner's matches, so he employed Mark "Slick" Johnson as his personal referee. Johnson had black and white paint on top of his head, wore an nWo logo on his shirt and had a whistle around his neck, just like ECW's Bill Alfonso. Another example of this is when Kurt Angle had Daivari as his personal referee