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 coach Sean Payton's home and family.
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.
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.
ESPN NFL Insider Adam Schefter contributed to this report.