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The lawsuit claims Cerullo created the document "well after the 2009 NFC Championship game and in an effort to gain revenge against the Saints."
The suit further contends that a "close associate" of Cerullo has confirmed that Cerullo retracted his previous claims about the bounty program "in a communication directly with Goodell that occurred in April 2012."
The lawsuit notes that Goodell has not shared notes from interviews with Cerullo. Goodell also did not produce Cerullo as a witness at the appeal hearing or acknowledge Cerullo's retraction.
However, Aiello has denied that key witnesses in the bounty probe have retracted statements.
Aiello also has said the NFL has not issued any gag orders. Vilma's latest lawsuit, however, claims the NFL has ordered suspended former Saints defensive coordinator Greg Williams not to speak with suspended Saints players, coaches or officials as a condition for his reinstatement.
The NFL has said that Williams, who is suspended indefinitely, organized a bounty system that offered cash for hits that injured opponents, and which ran during his three seasons as defensive coordinator in New Orleans from 2009-11.
A close friend and associate of Williams, who was present for at least one discussion Williams had with Goodell, contends Williams never acknowledged the existence of a bounty program, Vilma's lawsuit said.
Williams' associate also contends that Williams has no information corroborating NFL findings that Vilma offered a $10,000 bounty for knocking quarterbacks Kurt Warner or Brett Favre out of 2009-10 playoff games.
The same associate confirmed that Goodell ordered Williams not to speak about the bounty matter with other punished individuals, the lawsuit said.
[Associated Press;
Copyright 2012 The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.
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