1 Nigel Burns, Esq.

(SBN: 202576)
The Law Offices of Nigel Burns
2 660 Newport Center Drive, Suite 340
Newport Beach, California 92660
3 Telephone: (949) 718-0967
Facsimile: (949) 718-0937
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5 Attorneys for Defendants
JEFF BOHBOT aka JEFF HAMILTON, JEFF HAMILTON
6 INDUSTRIES, INC., and MERCEDES BOHBOT
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF LOS ANGELES – CENTRAL DISTRICT
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11 LAWFUND MANAGEMENT GROUP, LLC ) Case No.: BC375407
) ASSIGNED FOR ALL PURPOSES To:
12 and LFMG/JH, LLC, ) Judge William F. Fahey
) Department 78
13 Plaintiffs, )
) DECLARATION OF NIGEL BURNS IN
14 ) SUPPORT OF SUR-REPLY
)
15 vs. )
)
16 )
JEFF BOHBOT aka JEFF HAMILTON, an ) Date: Pending
17 )
individual, MERCEDES BOHBOT, an Time: 9:30 a.m.
)
18 individual, JEFF HAMILTON INDUSTRIES, ) Dept: 78
INC., TOM LALLAS, an individual, TOM )
19 LALLAS, P.C., a professional corporation, )
LEVY SMALL & LALLAS, a partnership, ) Action Filed: August 7, 2007
20 )
and DOES 1-50, inclusive, Trial Date: November 10, 2008
)
21 )
Defendants. )
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I, NIGEL BURNS, do hereby declare:
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1. I am an attorney licensed to practice before all courts in the State of California and
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am the principal of The Law Offices of Nigel Burns.
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2. I am the attorney of record for Defendants JEFF BOHBOT aka JEFF
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HAMILTON, MERCEDES BOHBOT, and JEFF HAMILTON INDUSTRIES, INC.
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______________________________________________________________________________________
DECLARATION OF NIGEL BURNS IN SUPPORT OF SUR-REPLY
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 1 (collectively “Defendants”) in the above-entitled action. I have personal knowledge of the
2 following facts and, if called upon to testify, I can and will testify competently thereto.
3 3. Mercedes was inadvertently and erroneously omitted from Defendants’ Opposition
4 to Application for TRO.
5 4. My firm mistakenly brought the Opposition to Application for TRO only on behalf
6 of Jeff and JHI and not on Mercedes’ behalf.
7 5. This mistake was a consequence of the fact that my firm demurred to the complaint
8 only on behalf of Jeff and JHI because Mercedes’ former counsel and co-defendant Tom Lallas
9 had answered the complaint on Mercedes’ behalf. When my firm filed a demurrer to the
10 complaint, Mercedes could not be included as she had already answered.
11 6. Due to inadvertence, Mercedes was consequently not included in subsequent
12 pleadings.
13 7. Mercedes should have been included as a defending party in the Opposition to
14 Application for TRO.
15 8. There is no evidence, other than Plaintiffs’ inflammatory and conclusory
16 statements, that Mercedes Bohbot has ever transferred or concealed assets in order to avoid
17 payment to creditors or that she intends to place her real properties on the market.
18 I declare under penalty of perjury under the laws of the State of California that the
19 foregoing is true and correct.
20 Executed on March ___, 2008, at Newport Beach, California.
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__________________________
22 NIGEL BURNS
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DECLARATION OF NIGEL BURNS IN SUPPORT OF SUR-REPLY
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