Only dirty fighters can argue with the refs.
Knowing this, set up an exhibition match with you using a high-ranked dirty fighter like Randy Orton or Rick Flair against a weak CPU opponent like Kelly Kelly (rating of 58).
Once the match starts, knock your opponent to the mat and try to pin them by pressing down with the right analog stick. When they kick out, press the Y button to argue with the referee. Do this four times.
Try and pin your enemy near the middle of the ring so they can't do a rope break.
After you've argued four times, just go on and win the match. If you're playing as a strong wrestler against a weak one, this achievement is easy.