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`IN THE CIRCUIT COURT FOR THE STATE OF OREGON FOR COOS COUNTY
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`KEELA JEAN WALLACE,
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`Case No. 2S CN) OCFTA
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`Petitioner,
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`vs.
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`STEVEN ANDREW MAYER,
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`Respondent.
`
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`MOTION TO APPEAR AND SHOW
`CAUSE; POINTS AND
`AUTHORITIES (EX PARTE)
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`Petitioner Keela Jean Wallace hereby moves the Court for an Order directing
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`Respondent Steven Andrew Mayer to appear and show cause as to why Mayershould not be
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`held in contempt of court for failing to comply with this Court’s Amended Limited Judgment
`
`RE: Temporary Relief dated July 2, 2024, and the General Judgment of Dissolution of
`Case No. 24YDR0SqOu
`Marriage dated October 24, 2024. This Motion is based on the records andfiles of this case,
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`ORS33.015-33.155, ORS 18.270, the Declarations of Emily Sarah Hill and Keela Jean
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`Wallace filed herewith (“Hill Decl.” and “Wallace Decl.,” respectively), and the following
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`Points and Authorities.
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`Mf
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`Il
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`Ml
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`Law Office of Emily S.Hill,
`P.C,
`2251 Ridgeway Drive
`Eugene, OR 97401
`(sil) aee2i7e
`emily@hulloregonlaw com
`
`PAGE 1 — MOTION FOR AN ORDER TO APPEAR AND SHOW CAUSE;
`POINTS AND AUTHORITIES(EX PARTE)
`
`
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`
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`POINTS AND AUTHORITIES
`
`The Court entered an Amended Limited Judgment RE: Temporary Relief on
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`July 2, 2024. Under that Amended Judgment, Petitioner was to "manage all aspects of
`Smoke on the Water, LLC." On July 7, 2024, Respondent filed a federal copyright
`application claiming full ownership of the LLC's logo. (Ex. 1 to Hill Decl.) The United
`States Copyright Office granted Respondent's application on October 17, 2024. (Ex. 1 to Hill
`Decl.) In fact, the LLC had held a contest and ultimately hired a company to design a logo
`for the LLC. Ownership of that logo was transferred to the LLC. A true copy of the Design
`Transfer Agreement is attached to the Hill Decl. as Exhibit 2. While Respondent signed the
`Design Transfer Agreement, he did so as a member of the LLC. Moreover, while he
`originally paid for the transfer of the logo out of his personal funds, the LLC later
`reimbursed him. As this Motion will further explain, Respondent has attempted to use his
`ownership of the logo to extort Petitioner into granting him an interest in the business after
`October 24, 2024, when the Court entered the General JJudgment of Dissolution of Marriage,
`as leverage for him not to appeal the General Judgment or sue Petitioner for copyright
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`infringement, and to cajole Petitioner into saying that she perjured herself in the domestic
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`relations proceedings.
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`The Amended Judgment also restricted the parties from texting more than twice if the
`other party did not respond to such texts. Respondent violated this order. Exhibit 1 to the
`Wallace Decl. reflects this disregard for the Court's authority. This exhibit contains one
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`VerifiedCorrectCopyofOriginal3/3/2025.
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`Law Office of Emily S. Hill,
`P.C.
`2251 Ridgeway Drive
`Eugene, OR 97401
`(541)344-2174
`emily@hilloregonlaw com
`
`AGE 2
`MOTION FOR AN ORDER TO APPEAR AND SHOW CAUSE;
`POINTS AND AUTHORITIES (EX PARTE)
`
`
`
`week's worth of text messages. Respondent texted Petitioner three times on October 4, 2024,
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`and eight times on October 9, 2024 and October 10, 2024. At one point, Petitioner requested
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`that Respondent not text her at 10:30 p.m., Respondent texted "Bruh, it's a text message.
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`You can ignore it." (Ex. 1 to Wallce Decl., Page 7) These texts are reflective of a pattern of
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`contact in violation of the Court's Amended Judgment. There are dozens more that have
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`been omitted here in the interest ofjudicial efficiency. Respondent's disregard for the
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`Court's authority in applying for a federal copyright reflecting sole ownership of the logo
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`created for the LLC, coupled with his excessive contact with Petitioner constitute contempt
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`of court.
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`Additionally, the Court's General Judgment of Dissolution of Marriage divided the
`assets and liabilities of the LLC in relevant part:
`"i. Wife shall be awarded 100% ownership of the business known as Smoke on the
`Water, LLC... as her sole and separate property, free from any estate, right, title or interest
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`Nog Husband, subject to paying Respondent his 25% share as set forth below.
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`ii. Husband shall immediately sign any bill of sale, title, or other conveyance
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`document necessary to release his interest in the business known as Smoke on the Water,
`LLC."
`
`The United States Copyright Office granted Respondent's copyright application on
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`October 17, 2024, one week before the Court's General Judgment. Rather than conveying the
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`Copyright ownership of the logo to Petitioner, Respondent has held the logo hostage in order
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`to extort Petitioner into granting him a role in the business, in exchange for him not
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`VerifiedCorrectCopyofOriginal3/3/2025.
`
`Law Office of Emily S. Hill,
`P.C.
`2251 Ridgeway Drive
`Eugene, OR 97401
`(541) 344-2174
`emily@hulloregonlaw com
`
`PAGE 3 - MOTION FOR AN ORDER TO APPEAR AND SHOW CAUSE;
`POINTS AND AUTHORITIES (EX PARTE)
`
`
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`appealing the General Judgment or suing Petitioner for copyright infringement, resulting in
`thousands of dollars in needless court fees, and trying to manipulate Petitioner into saying
`that she perjured herself during the domestic relations process. (Exhibit 2 to Wallace Decl.)
`For instance, Respondent indicated "J also officially have the federal copyright certificate for
`the logo. I don't care about the logo and would freely sign it over to you if we could be done.
`But if we're going to appeal, that's definitely not going to happen. You'll literally never own
`the rights to the logo if it goes to appeal." (Exhibit 2 to Wallace Decl., Page 1) On another
`occasion, he emailed "You don't even own the fucking logo, buddy. At the end of the day,
`I'm going to sue for lost profits, and the business is going to continue to underperform."
`(Exhibit 2 to Wallace Decl., Page 7) Exhibit 2, Pages 8 through 11 of the Wallace Decl.
`contain similar threats. As a result of these threats, Petitioner has not been able to market the
`LLC or to use the logo in connection with product development for fear that Respondent will
`file a suit for copyright infringement against her.
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`Defendant's flagrant conduct constitutes contempt of court. Plaintiff respectfully
`requests the Court grant sanctions under ORS 33.105 as follows:
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`1. Punitive sanctions in the amount of $10,000 in connection with Respondent's
`copyright application for the LLC's logo and his continued use of his fraudulent
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`ownership to sabotage Petitioner's business and personal interests;
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`2. Punitive sanctions in the amount of$1,500 for Respondent's excessive contact in
`violation of the Amended Judgment;
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`VerifiedCorrectCopyofOriginal3/3/2025.
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`Law Office of Emily S. Hill,
`P.C,
`2251 Ridgeway Drive
`Eugene, OR 97401
`(541) 344-2174
`emily@hilloregoniaw com
`
`PAGE 4-- MOTION FOR AN ORDER TO APPEAR AND SHOW CAUSE;
`POINTS AND AUTHORITIES (EX PARTE)
`
`
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`3. Remedial sanctions in the amount of $500 each day that Respondent does not
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`transfer ownership of the logo to Petitioner; and
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`4. Petitioner's attorney fees in the amount of $2,500 incurred in connection with the
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`filing of this Motion.
`
`DATED this @8" day of February, 2025.
`
`EMILY S. HILL (OSB No. 043152)
`Of Attorneys for Keela Jean Wallace
`Law Office of Emily S. Hill, P.C.
`2251 Ridgeway Drive
`Eugene, OR 97401
`(541) 344-2174
`emily@hilloregonlaw.com
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`VerifiedCorrectCopyofOriginal3/3/2025.
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`Law Office of Emily S. Hill,
`P.C.
`2251 Ridgeway Drive
`Eugene, OR 97401
`(541) 344-2174
`emily@hullor0001120970011
`
`PAGE 5~ MOTION FOR AN ORDER TO APPEAR AND SHOW CAUSE;
`POINTS AND AUTHORITIES (EX PARTE)
`
`
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