Vilma urges rejection of Goodell motion to dismiss

NEW ORLEANS (AP) — Jon Vilma urged a federal judge Friday to reject NFL Commissioner Roger Goodell's motion to dismiss the

defamation lawsuit filed against him by the Saints linebacker.

Vilma's request to U.S. District Judge

Ginger Berrigan argues Goodell acted with "reckless disregard for the

truth" when basing

initial allegations about Vilma upon one fired Saints assistant,

Mike Cerullo, whose testimony has been inconsistent and challenged

by other witnesses in the NFL's bounty probe of the Saints.

The motion centers on Goodell's public comments that Vilma held up $10,000 cash in a team meeting in 2010, offering it to

anyone who knocked Arizona quarterback Kurt Warner out of a playoff game.

During recent NFL appeal hearings in the bounty case, former Saints defensive coordinator Gregg Williams testified he never

saw any money.

"Williams has always told Goodell, and

continues to state, that there was never any cash put up for a bounty on

any player.

It was 'just talk.'" Vilma's motion reads. "Nonetheless, Goodell

irresponsibly chose to contend that Vilma walked around with

$10,000 before the Cardinals game."

Vilma's season-long suspension and with

various shorter bans for three other players were thrown out Tuesday by

former Commissioner

Paul Tagliabue, who Goodell had appointed to oversee the appeals

of player punishment.

After Tagliabue's decision, the NFL Players

Association dropped claims in federal court on behalf of Saints

defensive end

Will Smith and two former Saints: Cleveland linebacker Scott

Fujita and free agent defensive lineman Anthony Hargrove. Vilma

dropped his claims against the league concerning the disciplinary

process, but moved forward with his defamation case against

the commissioner, asking Berrigan to allow discovery, which

consists of the collection of evidence and deposing of witnesses.

Berrigan has so far delayed discovery while the Goodell's motion

to dismiss the case is pending.

In their effort to highlight how unreliable

Cerullo was, Vilma's attorneys, Peter Ginsberg and Duke Williams, cite

hearing

testimony from Saints assistant head coach Joe Vitt, who said

Payton once arranged for police protection at his former suburban

family home while he was away at league meetings because the head

coach feared Cerullo was emotionally unstable and might

harm his family.

While the lawsuit does not quote the testimony from the closed-door hearing directly, it appears in transcripts obtained by

The Associated Press.

"An email was sent to the League about Mike

Cerullo long before these (bounty) charges were brought up on our

football team

saying that Mike Cerullo was crazy, that Sean Payton had to have a

police escort or, excuse me, police protection at his house

because he was going to the owners' meeting, and he was worried

about his family with Cerullo," Vitt testified. "This is the

kind of guy we're dealing with. Allright?"

Vilma's motion also notes that the NFL subsequently dropped Goodell's initial allegation about Vilma physically holding up

money in the meeting before the Arizona game.

"There can no longer be any doubt that Goodell acted with malice ... in making this quasi-criminal accusation against Vilma,"

the motion said.

The NFL continues to allege that Vilma

offered a $10,000 to anyone who knocked then-Minnesota quarterback Brett

Favre out

of the 2010 NFC title game, which followed the Arizona game.

Williams testified that he recalled such an offer for that game,

but never saw any money change hands and suggested the offer

represented nothing more than tough talk in an emotional meeting

that he allowed to get out of hand.