ORIGINAL: early in
I haveread different opinions on this.
I can say for a fact that some deer paw the snow away before laying down, because I watchedthe buck I killed in Alberta do just that! I'll include a pic of it that I took. I think they do this soit puts them deeper into the snow for better insulating purposes. I watched my buck walk in my direction, and when he was about 60yrds out, he stopped and started pawing the snow, which wasclose toa foot deep. I thought he was making a scrape, until he layed down in it.

He stayed there for about 10-15 mins. I think he was just resting from the rigors of the rut. He got up, came towards me, and the rest is history.
You might have something there Early! I could see them doing it for that reason.