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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.Read More:*Vilma urges rejection of Goodell's try to dismiss lawsuit - NFL - SI.com

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Jonathan Vilma lawsuit against Roger Goodell paints Mike Cerullo as unstable - ESPN

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Vilma to add Cerullo document

A document outlining the reasons the New Orleans Saints fired then-defensive assistant Mike Cerullo will be added to the legal filings in linebacker Jonathan Vilma's defamation suit against commissioner Roger Goodell and the league, sources say.

The April 2010 memo from the Saints to the NFL details alleged Cerullo actions and lies that led team and league security to communicate about how to dismiss Cerullo, according to people familiar with the document. The plan included firing Cerullo away from the team facility and, as Vilma attorney Peter Ginsberg wrote in another filing last week, providing security for Sean Payton's home and family.

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Vilma and his legal team say they believe the document will further discredit Cerullo as the primary whistleblower on the Saints' bounty program.

The NFL utilized Cerullo's testimony as the basis of the allegations against the Saints and is assisting Cerullo with his legal fees.

Former commissioner Paul Tagliabue, in voiding the punishments Goodell levied against the players, portrayed Cerullo as a credible witness. However, Tagliabue ruled that inconsistencies in testimony, such as whether Vilma offered teammates money to knock former Cardinals quarterback Kurt Warner out of a 2009 divisional playoff game, arose from the Saints "contaminating" the NFL's investigation.

Tagliabue affirmed Goodell's finding that the Saints operated a bounty program, and he also found that Vilma, Saints defensive end Will Smith and former Saints nose tackle Anthony Hargrove engaged in conduct detrimental to the league. Tagliabue wrote that while fines may have been appropriate, Goodell's player suspensions were too harsh.

Vilma had been suspended for the entire season, Smith for four games and Hargrove eight, later reduced to seven games with five already served. Hargrove is not under contract with a team.

Tagliabue ruled there was no evidence of wrongdoing by linebacker Scott Fujita, now with the Browns. Goodell had previously reduced Fujita's four-game suspension to one.

Saints head coach Sean Payton remains suspended for the season. Former defensive coordinator Gregg Williams, now with the Rams, is suspended indefinitely. Sources tell ESPN that Williams is expected to apply for reinstatement soon.

Saints general manager Mickey Loomis served an eight-game suspension to start the season, and interim head coach Joe Vitt sat out six games.

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Rugby Saint II

Why would Sean Payton hang out with someone like that? After reading his book I feel like I know him............sorta'. I have always believed Payton is a good man who insists on high character players in the locker room.