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DECLARATION OF NIGEL BURNS IN SUPPORT OF SUR-REPLY

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 Nigel Burns, Esq. (SBN: 202576)The Law Offices of Nigel Burns660 Newport Center Drive, Suite 340 Newport Beach, California 92660Telephone: (949) 718-0967Facsimile: (949) 718-0937

Attorneys for DefendantsJEFF BOHBOT aka JEFF HAMILTON, JEFF HAMILTON

I NDUSTRIES, I NC., and MERCEDES BOHBOT

SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF LOS ANGELES – CENTRAL DISTRICT

LAWFUND MANAGEMENT GROUP, LLC

and LFMG/JH, LLC,

Plaintiffs,

vs.

JEFF BOHBOT aka JEFF HAMILTON, an

individual, MERCEDES BOHBOT, anindividual, JEFF HAMILTON INDUSTRIES,

INC., TOM LALLAS, an individual, TOMLALLAS, P.C., a professional corporation,

LEVY SMALL & LALLAS, a partnership,

and DOES 1-50, inclusive,

Defendants.

))))))))))))

))))))))))

Case No.: BC375407ASSIGNED FOR ALL PURPOSES To:Judge William F. FaheyDepartment 78

DECLARATION OF NIGEL BURNS IN

SUPPORT OF SUR-REPLY

Date: Pending

Time: 9:30 a.m.Dept: 78

Action Filed: August 7, 2007

Trial Date: November 10, 2008

I, NIGEL BURNS, do hereby declare:

1. I am an attorney licensed to practice before all courts in the State of California and

am the principal of The Law Offices of Nigel Burns.

2. I am the attorney of record for Defendants JEFF BOHBOT aka JEFF

HAMILTON, MERCEDES BOHBOT, and JEFF HAMILTON INDUSTRIES, INC.

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(collectively “Defendants”) in the above-entitled action. I have personal knowledge of the

following facts and, if called upon to testify, I can and will testify competently thereto.

3. Mercedes was inadvertently and erroneously omitted from Defendants’ Opposition

to Application for TRO.

4. My firm mistakenly brought the Opposition to Application for TRO only on behalf 

of Jeff and JHI and not on Mercedes’ behalf.

5. This mistake was a consequence of the fact that my firm demurred to the complaint

only on behalf of Jeff and JHI because Mercedes’ former counsel and co-defendant Tom Lallas

had answered the complaint on Mercedes’ behalf. When my firm filed a demurrer to the

complaint, Mercedes could not be included as she had already answered.

6. Due to inadvertence, Mercedes was consequently not included in subsequent

 pleadings.

7. Mercedes should have been included as a defending party in the Opposition to

Application for TRO.

8. There is no evidence, other than Plaintiffs’ inflammatory and conclusory

statements, that Mercedes Bohbot has ever transferred or concealed assets in order to avoid

 payment to creditors or that she intends to place her real properties on the market.

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

Executed on March ___, 2008, at Newport Beach, California.

 __________________________  NIGEL BURNS