Georgeann Walsh Ward, who met Simmons when he was a Big Apple school teacher in 1972 and said she dated him for three years, is objecting to Simmons calling her just one of his overpopulated harem of groupies on a VH1 documentary, reported the New York Post Saturday.
"There wasn't a girl that was off limits, and I enjoyed every one of them," Simmons said in the documentary, that showed Ward posing with Simmons. "I was a 24-hour whore, all I ever thought about was sex."
Simmons has estimated he has slept with 4,600 women.
The lawsuit alleges that the show implied that Ward "was similarly a sex-addicted nymphomaniac."
Ward, a married mother of a college-age child, is seeking unspecified money damages from Simmons, KISS and Viacom -- the parent company of cable TV's VH1 alleging Simmons and Viacom portrayed her as an "unchaste, sexually loose woman."