NEWORLEANS- In a strongly-worded memorandum to Judge Helen G. Berrigan, Saints linebacker Jonathan Vilma and his attorneys argue that Paul Tagliabue has a conflict of interest and should be removed as the arbitrator in the alleged 'bounty' case.

The suit argues that Tagliabue, the former commissioner and Goodell's former boss, practices law at a firm that serves as counsel for the NFL in 'all bounty-related matters'and that he is still one of the NFL's most highly-compensated employees.

'In appointing Tagliabue, Goodell has shown beyond any doubt that he simply cannot be allowed to apoint the arbitrator to adjudicate this matter...'said the memorandum.

Goodell recently appointed Tagliabue to arbitrate the matter after repeated complaints by the defendants and the player's union that Goodell shouldn't serve as the judge, jury and executioner.'

The suspended players - current Saints Will Smith and Jonathan Vilma, and former Saints Scott Fujita and Anthony Hargrove - have yet to serve any suspension as the appeals process continues.

Goodell recently reduced the penalties for most of the players involved, but the NFLPAcontinues to maintain that the process was flawed and that no real evidence has been presented.

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