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In the lawsuit, the players, as they have in the past, “categorically” deny participating in any kind of “bounty” program designed to injure fellow players, and the NFLPA adds that it would never defend who did conspire to injure their peers on the field.

“The investigation and arbitration process that the Commissioner’s public relations machinery touted as `thorough and fair’ has, in reality, been a sham,” the lawsuit stated.

The lawsuit said the NFL violated the labor agreement by refusing to provide the players with access to “critical documents or witnesses, or anything resembling the fairness mandated by the CBA and governing industrial due process law.”

The suit also states that the players were subject to arbitration before an arbiter in Goodell, who had “launched a public campaign defending the punishments he intended to arbitrate, rendering him incurably and evidently biased.”

The lawsuit also reiterates a claim that the CBA requires many of the “pay-for-performance” conduct outlined in the NFL’s bounty investigation to be handled by a system arbitrator and not the commissioner, who has “improperly usurped” control over that process.

The NFL has argued that the bounty matter falls under conduct detrimental to the league, which the commissioner has authority to punish. Two arbitration rulings so far have ruled in the NFL’s favor on that matter, but the NFLPA lawsuit says the NFL’s handling of the bounty matter amounts to a “rare case” in which the arbitrator’s rulings should be set aside.

The union contends the arbitrator, Stephen Burbank, made his decision based on the fact that he saw his jurisdiction covering only improper payments made to players, but not the payments the NFL has said players made into the bounty pool.

“This distinction cannot be justified by the CBA, nor can it override the fact that the NFLPA has never agreed to arbitrate these types of disputes before the Commissioner,” the lawsuit said.

Included with the 55-page lawsuit are 400 pages of exhibits, including about 200 pages of evidence that the NFL presented at a June 18 appeal hearing. The lawsuit notes that those documents represent a “sparse” sampling of the 18,000 documents totaling about 50,000 pages that the NFL said it had compiled during the three-year course of its investigation.

Also included is a sworn declaration from Duke Naipohn, a fatigue risk management specialist who was working closely with the Saints defense throughout the 2011 season. Naipohn said he attended most defensive meetings and never saw bounties placed on opposing players or saw Saints players rewarded for injuring opponents.