By Jen Heger - Breaking Celebrity News Legal Editor

Lindsay Lohan is putting on notice the Hookah manager who claims she hit him with her Porsche as she left a Hollywood nightclub that if he files a civil lawsuit against her the actress will counter-sue and will hold him responsible for the allegations he has made, Breaking Celebrity News is exclusively reporting.

As we previously reported Lohan, 25, was leaving Sayers Club in Hollywood shortly after midnight last Wednesday in her new black Porsche when she was blocked by a swarm of paparazzi and club patrons from the nearby Hookah Lounge.

As she attempted to navigate a three point turn to get out of the alley, she allegedly grazed the manager of the Hookah Lounge. Initially, a source close to the situation told Breaking Celebrity News, the manager told cops at the scene that he wasn’t hit by the car, but after finding out that Lohan was the driver, the manager went to a hospital emergency room