Jonathan Vilma Requests To See NFL's Bounty Evidence Against Him

May 7, 2012
Via E-Mail
Roger Goodell
Commissioner
National Football League
345 Park Avenue
New York, NY 10017

RE: Jonathan Vilma
Dear Commissioner Goodell:

We are writing on behalf of our client Jonathan Vilma. Mr. Vilma, along with other NFL players, has filed pleadings in two other forums seeking to resolve the issue of the proper jurisdiction to address the instant dispute alleging his participation in a so-called "pay-for-performance/bounty" program at various times during the 2009, 2010 and 2011 seasons. Those pleadings have been filed before the System Arbitrator, pursuant to Article 14, Section 3 and Article 15, Section 1 of the August 4, 2011 CBA, and before the Non-Injury Grievance Arbitrator, seeking an order of compliance with Article 3, Section 3(b). We are also obviously aware that you have attempted to impose discipline pursuant to a Notice dated May 2, 2012.

As you are aware, we have previously requested your Office to provide evidence gathered during the course of the NFL's investigation that supports, corroborates or relates in any way to the many allegations you and the NFL have disseminated in the media regarding Mr. Vilma's alleged participation in a purported bounty program and which in summary form is described in your May 2, 2012 Notice setting forth Mr. Vilma's proposed punishment. The NFL has refused to provide a single piece of evidence to us. That approach to this serious matter was reflected in the NFL's outside counsel's disturbing recent statement to the media that the players' requests to review and understand the alleged evidence against them is a "red herring.' Rather, to be able to share, discuss and analyze the supposed evidence that has been gathered is a fundamental cornerstone of a fair and just process, and a vital prerequisite to uncovering the truth. Indeed, the failure of the NFL to conduct itself in a just manner has compromised the process and resulted in erroneous and damaging conclusions.

As we prepare for future proceedings, we request the NFL to provide immediately the following in order to assure that resolution of this dispute not be delayed and that Mr. Vilma has a fair opportunity as quickly as possible to remedy the harm that is being done to his reputation and to his career:

1. All documents and communications evidencing a "pay-for-performance/bounty" program, including, but not limited to, any ledger, notebook, record or record book, payment slip, note or entry of any sort, or evidencing that no such "pay-for-performance/bounty" program existed and/or involved Mr. Vilma;
2. All documents and communications evidencing that Mr. Vilma established, or assisted in establishing, a "pay-for-performance/bounty" program or any other program in violation of NFL rules, or evidencing that Mr. Vilma did not have a role in establishing, or assisting in the establishment of, such "pay-for-performance/bounty" program;
3. All documents and communications evidencing that Mr. Vilma "pledged," made or received payments of any kind resulting from an opposing player being carried off the field, i.e., "cart-offs," including but not limited to any ledger, notebook, record or record book, payment slip, note or entry of any sort, or evidencing that Mr. Vilma did not "pledge," make or receive payments resulting from an opposing player being carried off the field, i.e., "cart-offs"
4. All documents and communications evidencing that Mr. Vilma "pledged," made or received payments of any kind resulting from an opposing player being unable to return to the game, i.e., "knockouts," including but not limited to any ledger, notebook, record or record book, payment slip, note or entry of any sort, or evidencing that Mr. Vilma did not "pledge," make or receive payments resulting from an opposing player being unable to return to the game, i.e., "knockouts";
5. All documents and communications evidencing that Mr. Vilma "pledged," made or received payment of any kind resulting from an opposing player being injured, including but not limited to any ledger, notebook, record or record book, payment slip, note or entry of any sort, or evidencing that Mr. Vilma did not "pledge," make or receive payments resulting from an opposing player being injured;
6. All documents and communications evidencing that Mr. Vilma "targeted" an opposing player in any manner that would violate NFL rules, or evidencing that Mr. Vilma did not "target" an opposing player in any manner;
7. All documents and communications evidencing that Mr. Vilma engaged "in unsafe and prohibited conduct intended to injure players" or did not engage "in unsafe and prohibited conduct intended to injure players";
8. All documents and communications evidencing that Mr. Vilma "participate[d] in a program that potentially injured opposing players," or evidencing that Mr. Vilma did not "participate[d] in a program that potentially injured opposing players";
9. All documents and communications evidencing that Mr. Vilma "embraced" a "pay-for-performance/bounty" program or any other program in violation of NFL rules, or evidencing that Mr. Vilma did not "embrace" a "pay-for-performance/bounty" program or any other program in violation of NFL rules;
10. All documents and communications evidencing that Mr. Vilma offered, paid or intended to pay $10,000, or any amount of money, to any player for knocking Kurt Warner, Brett Favre, and/or any other player, out of the 2009 Divisional Playoff Game, 2010 NFC Championship Game, or any other game, or evidencing that Mr. Vilma did not engage in such activity;
11. All statistics of any nature gathered in the course of the 'bounty program' investigation relating to penalties assessed against Mr. Vilma and all other New Orleans Saints players during the years 2009 - 2011;
12. All game film of New Orleans Saints games and players gathered in the course of the `bounty program' investigation of exhibition games, regular season games and playoff and championship games during the years 2009 - 2011;
13. All tape recordings of any sort gathered in the course of the 'bounty program' investigation relating to meetings of any sort that occurred during the years 2009 - 2011;
14. All witness statements, notes of interviews and declarations gathered during the course of the 'bounty program' investigation;
15. The names and identification of all persons interviewed by the NFL and all persons acting on behalf of the NFL during the course of the 'bounty program' investigation;
16. The names and identification of all witnesses the NFL plans to present at Mr. Vilma's Appeal Hearing; and
17. All evidence the NFL plans to offer or use in any manner at Mr. Vilma's Appeal Hearing.

Thank you for your consideration of the above.
Sincerely,