| 5/12/2025 2:53 PM
`25CN00972
`
`3
`
`4 |
`
`5
`
`6 | IN THE CIRCUIT COURT FOR THE STATE OF OREGON FOR COOS COUNTY
`
`7 | KEELA JEAN WALLACE, Case No. 25CN00972
`
`: Plaintiff, AMENDED COMPLAINT TO SHOW
`
`9 CAUSE
`
`VS.
`10 Remedial Sanctions Sought
`STEVEN ANDREW MAYER,
`11 Related to Coos County Circuit Court Case
`Defendant. No. 24DR03804
`
`12
`
`13 || Plaintiff Keela Jean Wallace (“Plaintiff or “Petitioner”) hereby moves the Court for
`“ an Order directing Defendant Steven Andrew Mayer (“Defendant” or “Respondent”) to
`
`15
`
`1 appear and show cause as to why Mayer should not be held in contempt of court for failing
`i7 || to comply with this Court’s Amended Limited Judgment RE: Temporary Relief dated July 2,
`18 || 2024, and the General Judgment of Dissolution of Marriage dated October 24, 2024 (Coos
`
`|
`19 Recent . . . , ; ;
`County Circuit Court Case No. 24DR03804- Marriage Dissolution Proceeding). This Motion
`
`20
`' is based on the records and files of this case, ORS 33.015-33.155, ORS 18.270, the
`mm) Declarations of Emily Sarah Hill and Keela Jean Wallace filed herewith (“Hill Decl.” and
`
`| “Wallace Decl.,” respectively), and the following Points and Authorities.
`
`24 ||
`95 || //
`
`26 |) ///
`
`|
`
`Law Office of Emily S. Hill,
`P.C,
`2251 Ridgeway Drive
`Eugene, OR 97401
`(541) 344-2174
`emily@hilloregonlaw.com
`
`PAGE 1 —- AMENDED COMPLAINT TO SHOW CAUSE
`
`
`
`
`
`
`
`
`
`POINTS AND AUTHORITIES
`
`3 The Court entered an Amended Limited Judgment RE: Temporary Relief in Coos
`
`4 || County Circuit Court Case No. 24DR03804 on 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.
`g || (Ex. | to Hill Decl.) The United States Copyright Office granted Respondent’s application
`
`9 || 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
`13 | 2. While Respondent signed the Design Transfer Agreement, he did so as a member of the
`
`\4 | 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
`
`ig | the business after October 24, 2024, when the Court entered the General Judgment of
`
`19 | Dissolution of Marriage, as leverage for him not to appeal the General Judgment or sue
`
`8 Petitioner for copyright infringement, and to cajole Petitioner into saying that she perjured
`21
`
`6 herself in the domestic relations proceedings.
`
`23
`
`7 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 | to the
`
`26 || Wallace Decl. reflects this disregard for the Court’s authority. This exhibit contains one
`
`Law Office of Emily S. Hill,
`P.C,
`225] Ridgeway Drive
`Eugene, OR 97401
`(541) 344-2174
`emily @hilloregonlaw.com
`
`PAGE 2 —- AMENDED COMPLAINT TO SHOW CAUSE
`
`
`
`
`
`
`
`
`bho
`
`lo
`
`week’s worth of text messages. Respondent texted Petitioner three times on October 4, 2024,
`and eight times on October 9, 2024 and October 10, 2024. At one point, Petitioner requested
`that Respondent not text her at 10:30 p.m., Respondent texted “Bruh, it’s a text message.
`You can ignore it.” (Ex. 1 to Wallce Decl., Page 7) These texts are reflective of a pattern of
`contact in violation of the Court’s Amended Judgment. There are dozens more that have
`been omitted here in the interest of judicial efficiency. Respondent’s disregard for the
`Court’s authority in applying for a federal copyright reflecting sole ownership of the logo
`created for the LLC, coupled with his excessive contact with Petitioner constitute contempt
`of court.
`
`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
`of Husband, subject to paying Respondent his 25% share as set forth below.
`
`ii. Husband shall immediately sign any bill of sale, title, or other conveyance
`document necessary to release his interest in the business known as Smoke on the Water,
`ELG.”
`
`The United States Copyright Office granted Respondent’s copyright application on
`October 17, 2024, one week before the Court’s General Judgment. Rather than conveying the
`copyright ownership of the logo to Petitioner, Respondent has held the logo hostage in order
`
`to extort Petitioner into granting him a role in the business, in exchange for him not
`
`Law Office of Emily S. Hill,
`
`P;C.
`
`225] Ridgeway Drive
`
`Eugene, OR
`
`97401
`
`(541) 344-2174
`emily@hilloregonlaw.com
`
`PAGE 3 —- AMENDED COMPLAINT TO SHOW CAUSE
`
`
`
`
`
`
`
`
`tw
`
`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 “I 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.
`
`Defendant's flagrant conduct constitutes contempt of court. Plaintiff respectfully
`
`requests the Court grant sanctions under ORS 33.105 as follows:
`
`1. Remedial sanctions in the amount of $10,000 to compensate Petitioner for loss and
`injury sustained in connection with Respondent’s fraudulent copyright registration
`for the LLC’s logo and her corresponding inability to market the LLC.
`
`2. Remedial sanctions in the amount of $1,500 for Respondent’s excessive contact in
`
`violation of the Amended Judgment.
`
`Law Office of Emily S. Hill,
`
`B.C.
`
`2251 Ridgeway Drive
`
`Eugene, OR
`
`97401
`
`(541) 344-2174
`emily@hilloregonlaw,com
`
`PAGE 4— AMENDED COMPLAINT TO SHOW CAUSE
`
`
`
`
`
`
`
`
`l 3. Remedial sanctions in the amount of $500 each day that Defendant does not
`transfer ownership of the logo to Plaintiff; and
`
`4. Plaintiff's attorney fees in the amount of $2,500 incurred in connection with the
`
`4
`5 filing of this Motion.
`
`6
`
`, DATED this \9 day of May, 2025.
`8
`
`°| MALS
`
`iI EMILY S. HILL (OSB No. 043152)
`Of Attorneys for Keela Jean Wallace
`a Law Office of Emily S. Hill, P.C.
`
`13 2251 Ridgeway Drive
`
`Eugene, OR 97401
`
`14 (541) 344-2174
`
`- emily @hilloregonlaw.com
`
`Law Office of Emily S. Hill,
`PC;
`2251 Ridgeway Drive
`Pugene, OR 97401
`(541) 344-2174
`emily@hilloregonlaw.com
`
`PAGE 5 - AMENDED COMPLAINT TO SHOW CAUSE
`
`
`
`
`
`
`
`
`
`25CN00972
`
`3
`
`4 |
`
`5
`
`6 | IN THE CIRCUIT COURT FOR THE STATE OF OREGON FOR COOS COUNTY
`
`7 | KEELA JEAN WALLACE, Case No. 25CN00972
`
`: Plaintiff, AMENDED COMPLAINT TO SHOW
`
`9 CAUSE
`
`VS.
`10 Remedial Sanctions Sought
`STEVEN ANDREW MAYER,
`11 Related to Coos County Circuit Court Case
`Defendant. No. 24DR03804
`
`12
`
`13 || Plaintiff Keela Jean Wallace (“Plaintiff or “Petitioner”) hereby moves the Court for
`“ an Order directing Defendant Steven Andrew Mayer (“Defendant” or “Respondent”) to
`
`15
`
`1 appear and show cause as to why Mayer should not be held in contempt of court for failing
`i7 || to comply with this Court’s Amended Limited Judgment RE: Temporary Relief dated July 2,
`18 || 2024, and the General Judgment of Dissolution of Marriage dated October 24, 2024 (Coos
`
`|
`19 Recent . . . , ; ;
`County Circuit Court Case No. 24DR03804- Marriage Dissolution Proceeding). This Motion
`
`20
`' is based on the records and files of this case, ORS 33.015-33.155, ORS 18.270, the
`mm) Declarations of Emily Sarah Hill and Keela Jean Wallace filed herewith (“Hill Decl.” and
`
`| “Wallace Decl.,” respectively), and the following Points and Authorities.
`
`24 ||
`95 || //
`
`26 |) ///
`
`|
`
`Law Office of Emily S. Hill,
`P.C,
`2251 Ridgeway Drive
`Eugene, OR 97401
`(541) 344-2174
`emily@hilloregonlaw.com
`
`PAGE 1 —- AMENDED COMPLAINT TO SHOW CAUSE
`
`
`
`
`
`
`
`
`
`POINTS AND AUTHORITIES
`
`3 The Court entered an Amended Limited Judgment RE: Temporary Relief in Coos
`
`4 || County Circuit Court Case No. 24DR03804 on 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.
`g || (Ex. | to Hill Decl.) The United States Copyright Office granted Respondent’s application
`
`9 || 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
`13 | 2. While Respondent signed the Design Transfer Agreement, he did so as a member of the
`
`\4 | 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
`
`ig | the business after October 24, 2024, when the Court entered the General Judgment of
`
`19 | Dissolution of Marriage, as leverage for him not to appeal the General Judgment or sue
`
`8 Petitioner for copyright infringement, and to cajole Petitioner into saying that she perjured
`21
`
`6 herself in the domestic relations proceedings.
`
`23
`
`7 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 | to the
`
`26 || Wallace Decl. reflects this disregard for the Court’s authority. This exhibit contains one
`
`Law Office of Emily S. Hill,
`P.C,
`225] Ridgeway Drive
`Eugene, OR 97401
`(541) 344-2174
`emily @hilloregonlaw.com
`
`PAGE 2 —- AMENDED COMPLAINT TO SHOW CAUSE
`
`
`
`
`
`
`
`
`bho
`
`lo
`
`week’s worth of text messages. Respondent texted Petitioner three times on October 4, 2024,
`and eight times on October 9, 2024 and October 10, 2024. At one point, Petitioner requested
`that Respondent not text her at 10:30 p.m., Respondent texted “Bruh, it’s a text message.
`You can ignore it.” (Ex. 1 to Wallce Decl., Page 7) These texts are reflective of a pattern of
`contact in violation of the Court’s Amended Judgment. There are dozens more that have
`been omitted here in the interest of judicial efficiency. Respondent’s disregard for the
`Court’s authority in applying for a federal copyright reflecting sole ownership of the logo
`created for the LLC, coupled with his excessive contact with Petitioner constitute contempt
`of court.
`
`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
`of Husband, subject to paying Respondent his 25% share as set forth below.
`
`ii. Husband shall immediately sign any bill of sale, title, or other conveyance
`document necessary to release his interest in the business known as Smoke on the Water,
`ELG.”
`
`The United States Copyright Office granted Respondent’s copyright application on
`October 17, 2024, one week before the Court’s General Judgment. Rather than conveying the
`copyright ownership of the logo to Petitioner, Respondent has held the logo hostage in order
`
`to extort Petitioner into granting him a role in the business, in exchange for him not
`
`Law Office of Emily S. Hill,
`
`P;C.
`
`225] Ridgeway Drive
`
`Eugene, OR
`
`97401
`
`(541) 344-2174
`emily@hilloregonlaw.com
`
`PAGE 3 —- AMENDED COMPLAINT TO SHOW CAUSE
`
`
`
`
`
`
`
`
`tw
`
`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 “I 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.
`
`Defendant's flagrant conduct constitutes contempt of court. Plaintiff respectfully
`
`requests the Court grant sanctions under ORS 33.105 as follows:
`
`1. Remedial sanctions in the amount of $10,000 to compensate Petitioner for loss and
`injury sustained in connection with Respondent’s fraudulent copyright registration
`for the LLC’s logo and her corresponding inability to market the LLC.
`
`2. Remedial sanctions in the amount of $1,500 for Respondent’s excessive contact in
`
`violation of the Amended Judgment.
`
`Law Office of Emily S. Hill,
`
`B.C.
`
`2251 Ridgeway Drive
`
`Eugene, OR
`
`97401
`
`(541) 344-2174
`emily@hilloregonlaw,com
`
`PAGE 4— AMENDED COMPLAINT TO SHOW CAUSE
`
`
`
`
`
`
`
`
`l 3. Remedial sanctions in the amount of $500 each day that Defendant does not
`transfer ownership of the logo to Plaintiff; and
`
`4. Plaintiff's attorney fees in the amount of $2,500 incurred in connection with the
`
`4
`5 filing of this Motion.
`
`6
`
`, DATED this \9 day of May, 2025.
`8
`
`°| MALS
`
`iI EMILY S. HILL (OSB No. 043152)
`Of Attorneys for Keela Jean Wallace
`a Law Office of Emily S. Hill, P.C.
`
`13 2251 Ridgeway Drive
`
`Eugene, OR 97401
`
`14 (541) 344-2174
`
`- emily @hilloregonlaw.com
`
`Law Office of Emily S. Hill,
`PC;
`2251 Ridgeway Drive
`Pugene, OR 97401
`(541) 344-2174
`emily@hilloregonlaw.com
`
`PAGE 5 - AMENDED COMPLAINT TO SHOW CAUSE
`
`
`
`
`
`
`
`
`
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