Jonathan Vilma disputes Mike Cerullo's credibility in latest legal filing

New Orleans Saints linebacker Jonathan Vilma is calling into question the credibility of one of the NFL's primary bounty witnesses, former defensive assistant Mike Cerullo, and the league's assertion that there was a bounty on Arizona quarterback Kurt Warner. Vilma and his attorney, Peter Ginsberg, are attempting to keep Vilma's defamation suit against NFL Commissioner Roger Goodell moving forward in U.S. District Court.

The details on Cerullo were part of a memo filed in opposition of Goodell's motion for Judge Ginger Berrigan to dismiss the defamation lawsuit.

The memo said Cerullo is the only person to claim Vilma put a bounty on Kurt Warner and Ginsberg claimed that the NFL doesn't believe Cerullo's account.

"Cerullo was fired for his incompetence and repeated and material lies to the Saints which caused him to miss several weeks of the 2009 season," Ginsberg wrote.

The biggest allegation is that Saints Coach Sean Payton had to obtain police protection at his home after the team fired Cerullo.

The memo also said Cerullo claimed that Mike Ornstein gave his $10,000 to Gregg Williams at a hotel the night before the NFC divisional playoff game against Arizona.

"Williams, as with the other Cerullo fantasies, never told Goodell that this accusation was true," Ginsberg said in the memo.

The memo also said Cerullo's story changed concerning whether he memorialized the supposed bounties on Warner.

"On November 13, 2011, Cerullo told Goodell and his investigators that he had taken 'detailed notes' about the supposed bounties on Warner," Ginsberg said in the memo. "Of course, no such notes were ever provided, as Goodell clearly knew, and Cerullo later denied taking any such notes."

The memo claimed Cerullo manufactured a spreadsheet of bounties "that even the NFL could not believe."

"The spreadsheet contended that the Saints defensive team and staff pledged an improbable $235,500 during the playoffs," Ginsberg said in the memo. "Cerullo now admits he has no explanation for the outrageous amounts shown on his spreadsheet."

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