LOS ANGELES - A woman filed a proposed class-action lawsuit in Los Angeles against writer James Frey over his controversial memoir about his recovery from drug and alcohol abuse, court paper showed Friday.

Earlier this week, The Smoking Gun, an investigative Web site, alleged that Frey fabricated some information in his book, "A Million Little Pieces," including his criminal record.

More than 3 1/2 million copies of the memoir, which was selected for Oprah Winfrey's book club, have been sold since it was published in 2003 by Random House's Doubleday division.

A message left after regular business hours with Doubleday publicist Alison Rich, seeking comment on the lawsuit, was not immediately returned.

In her complaint filed Thursday in Los Angeles Superior Court, Sara Rubenstein says she read the book last summer.

"Plaintiff made her purchase in reliance upon defendants' deceptive, fraudulent and false representations that the book was a non-fiction literary work," the suit states. "Plaintiff would not have purchased the book had defendants truthfully disclosed that many of the events portrayed in the book were fiction."

Rubenstein wants a judge to order Frey and co-defendant Random House to refund the cost of the book to all California readers who bought it between 2003 and this week.

She is also seeking restitution for class members and a court order requiring the defendants "to publish notice of the truth regarding the book."

At least one other lawsuit has been filed against Doubleday over Frey's memoir. Pilar More, a mother of two, sued Doubleday in Cook County, Ill., alleging consumer fraud and seeking unspecified damages.