In papers filed Monday in Los Angeles Superior Court, David Kim claims he was hired by the star via "various oral and text messages" to provide personal security at a rate of $4,000 per week for 24-hour service – but never got paid.
The suit alleges that Kim accompanied Lohan, 21, to industry events, protected her from fans and paparazzi, paid gratuities to the staff and valets at venues where the actress partied out of his own pocket and was never reimbursed.
Kim claims he was contracted from Oct. 13, 2006, to March 10, 2007, and is owed more than $55,000 in unpaid wages alone. In addition, he says Lohan's driver caused nearly $1,500 worth of damage to Kim's personal car while making an illegal turn trying to get away from the paparazzi.
The lawsuit, which also names Lohan's company Crossheart Productions as a defendant, says the actress breached an oral contract with Kim and violated a host of labor codes.
A rep for the Lohan tells PEOPLE: "I'm not aware of that bodyguard. I've never even heard of that person."
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