The suit says Ryan Simkin, 34, has a "Tell-All" book ready that will detail incidents involving drugs, sex and jail. The NDA prohibits Simkin from "writing and publishing any tell-all books about their work," the suit said.
Francis, according to TMZ, also is suing the publisher and said that all Mantra employees must sign the agreement. Mantra is the parent company of the Girls Gone Wild line of products.
Simkin, a former Mantra production manager, worked for Mantra for several years, beginning in 2002.
In 2003, Simkin, along with two others Mantra employees and Francis, were arrested in Panama City after local underage girls claimed they posed for Girls Gone Wild. The girls eventually sued Francis, Simkin, associate Mark Schmitz and Mantra.
“Unfortunately, Simkin has decided that money and fame are more important to him than keeping promises,” the suit says.
Simkin’s book, titled “Flash! Bars, Boobs, And Busted: 5 Years On The Road With Girls Gone Wild,” purports to be “the definitive behind-the-scenes account” of the inner workings of Girls Gone Wild.