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NFLPA has responded:

Via PFT's Florio

"Predictably (given the inability of the NFL and NFLPA to agree on anything right now), Smith disagrees with Goodell’s contention. “At no point did I reach some sort of agreement with Mr. Goodell that, in exchange for delaying the NFL’s imposition of discipline on players, the NFLPA would conduct its own investigation and share the results of that investigation with the NFL,” Smith said in a sworn statement filed with the court on Friday, a copy of which PFT has obtained.

Smith also takes advantage of the opportunity to fire another shot at the league’s overall process.

“I stressed to Mr. Goodell that it was important for the accused players and the NFLPA to have access to the League’s information, and that the information be presented so that the accused players could respond before any punishment was imposed,” Smith said. “Finally, I emphasized that transparency was important, so that if there were clear evidence of a pay-to-injure program, the NFLPA could work with the NFL to stop such behavior and ensure it never happens again. The cooperation and transparency that I requested, and that I firmly believed was in the best interest of all parties, was not provided and to date, it has never been provided.”

Taking it all one level higher, Browns linebacker Scott Fujita executed an affidavit in which he directly disputes the claim that Goodell was ready to discipline the players as of March 21. Fujita testifies that he called Goodell on “approximately” March 20, because Fujita was “disturbed that my name had been leaked in media reports concerning the NFL’s investigation.” Fujita then testifies that, during the call, “Goodell told me he would be coming down hard with punishments on the Saints coaches, but that with respect to Saints players, he was not quite sure what he had on them, and that player punishments therefore would take some time.”

In other words, the NFLPA believes that Goodell’s sworn statement was unintentionally inaccurate, at best."

Smith, Fujita dispute Goodell’s sworn statement on March 21 issue | ProFootballTalk



In the NFL's submission to the judge yesterday, Goodell states that AFTER he sent the letter on 3/14 to the NFLPA to deny the request to delay the punishments... he and Smith talked on the phone a few days later to agree to delay the punishments.

Smith is essentially denying that this supposed "phone call" happened. I knew that would happend......