2014 HOCKEY ARBITRATION COMPETITION OF CANADA Derick Brassard vs. New York Rangers Submission on behalf of the New York Rangers Midpoint: $5 Million

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1 2014 HOCKEY ARBITRATION COMPETITION OF CANADA Derick Brassard vs. New York Rangers Submission on behalf of the New York Rangers Midpoint: $5 Million Submission by Team 2 1

2 Table of Contents I. INTRODUCTION... 3 II. OVERALL PERFORMANCE OF THE PLAYER... 4 A. Career Performance... 4 Table 1: Regular Season Statistics for Derick Brassard... 4 III. CONTRIBUTION TO THE CLUB... 5 B. Playoff Performance... 5 Table 2: Postseason Statistics for Derick Brassard... 5 IV. INJURIES AND ILLNESSES... 6 V. COMPARABLE PLAYERS... 6 A. Patrick Berglund (St-Louis Blues)... 6 B. Max Pacioretty (Montreal Canadiens)... 8 C. Chris Stewart (Buffalo Sabres)

3 I. INTRODUCTION The following brief shall introduce and discuss the salary arbitration case involving Mr. Derick Brassard (hereafter referred to as "Mr. Brassard" or "the Player"), a 26 year-old NHL player. The present brief shall expose Mr. Brassard's aptitudes in the professional sport of hockey in order to discuss and provide the necessary evidentiary support to an arbitration award for a future contract with the New York Rangers (hereafter referred to as "the Club"). As a restricted free agent, Mr. Brassard is eligible for salary arbitration under the NHL Collective Bargaining Agreement (hereafter referred to as the "CBA"), and having manifested his interest to opt for salary arbitration, the Club, in response, shall demonstrate within the present brief, evidence to contradict Mr. Brassard's position with regards to the salary award. According to article 12 of the CBA, only specific elements of evidence can be introduced as proof, which take into account Mr. Brassard's previous seasons in the NHL, and shall thus provide the necessary support to arrive at a just arbitration award. The evidence that the present brief shall expose are the following elements: the total number of NHL games played by the Player in his career; the total number and length of injuries or illnesses that have affected the player throughout his career; the length of service of the Player; the overall contribution of the Player to the club in the season (platformyear); the overall performance of the Player throughout his career; the overall performance of the Player in the NHL playoffs; the overall performance of eligible comparable players according to article 12 of the CBA. The comparable players shall provide the arbitrator to quantify and qualify the Player's salary arbitration claim in order to arrive at a just award. 3

4 In evaluating all the relevant criteria, it is the Club's position and understanding that Mr. Brassard, despite his talented aptitude within the sport of hockey, should be entitled to less than the $5 Million midpoint. The Club shall therefore respectfully demonstrate that an amount of $3.9 Million arbitration award is a just and reasonable amount for the Player considering all the pertinent evidence enumerated within the present brief. II. OVERALL PERFORMANCE OF THE PLAYER A. Career Performance Table 1: Regular Season Statistics for Derick Brassard 1 CAREER REGULAR SEASON STATISTICS SEASON TEAM GP G A P +/- PIM PPG SHG GWG S S% BLUE JACKETS BLUE JACKETS BLUE JACKETS BLUE JACKETS BLUE JACKETS BLUE JACKETS RANGERS RANGERS NHL TOTALS Selected by the Columbus Blue Jackets with the 6 th overall pick in the NHL 2006 draft, Mr. Brassard made his debut in the NHL during the season with the Columbus Blue Jackets. Mr. Brassard has achieved a career high of 18 goals in a single season, to which he participated in 81 games. With regards to his career total, Mr. Brassard accumulated 81 goals and 225 points in 404 games played, for an average 0.2 goals/game and 0.56 points/game. As demonstrated in Table 1, Mr. Brassard has been consistently been around the points/season 1 4

5 mark, however this notion is only applicable with regards to the seasons in which he played more than 70 games. In the previous season, by scoring 45 points, Mr. Brassard ranked 4th on the team 2 in total points. During his time with the New York Rangers, Mr. Brassard played an average of 15:54 min per game 3. III. CONTRIBUTION TO THE CLUB B. Playoff Performance Table 2: Postseason Statistics for Derick Brassard 4 SEASON TEAM GP G A P +/- PIM PPG SHG GWG S S% RANGERS RANGERS NHL TOTALS Admittedly, Mr. Brassard's skills have proven particularly useful in the postseason. In his two trips to the playoffs with the Club, Mr. Brassard scored 8 goals and 24 points in 35 games, for an average of 0.69 points/game. Nevertheless, the Club is of the opinion that while Mr. Brassard's playoff stats are good, Mr. Brassard must elevate his game during the regular season, since a team must first perform well in the season in order to make it to the playoffs Hockey-Reference.com

6 IV. INJURIES AND ILLNESSES During his career, Mr. Brassard suffered from a few major injuries. He missed some games in playoffs 5, but more importantly in 2008, while leading the NHL as the best Rookie scorer of the League, Mr. Brassard suffered a dislocated shoulder after a fight with James Neal. As a result of this, Mr. Brassard had to undergo surgery and missed most of the season, appearing in only 31 games. Moreover, this was the second time the Player suffered from a dislocated shoulder; the first being during his last year with his QMJHL team (Drummondville). As such, the clinisity and recurrence of his shoulder injury have been the cause for some doubt in the mind of the Club as to the Player's longevity and ability to remain healthy. Therefore, due to the notion of lagging potential injury liability, the Club is of the opinion that said liability should be quantified in a negative manner with regards to the award of any monies. V. COMPARABLE PLAYERS A. Patrick Berglund (St-Louis Blues) Patrick Berglund is a 26 year-old second-line center with the St-Louis Blues. 6 Mr. Berglund was selected 25 th overall by the Blues of the 2006 NHL Entry Draft. 7 Given the fact that both players were drafted the same year, in the same round furthers the notion that they both had a similar expectation potential, and similar experience in the NHL. Furthermore, considering that both players are centers and are of similar size, coupled with the notion that Mr. Berglund is an eligible comparable under the CBA, he is a perfect comparable for Mr. Brassard

7 Table 3: Career statistics for Patrick Berglund SEASON TEAM GP G A P +/ - PPG SHG BLUES BLUES BLUES BLUES BLUES BLUES NHL TOTALS Mr. Berglund has been in the league for 6 seasons and has played 436 games as compared to Mr. Brassard's total of 403GP. Mr. Berglund has recorded 106 goals and 114 assists for a career total of 220 points. Mr. Brassard has recorded 81 goals and 144 assists for a career total of 225 points 8. Furthermore, Mr. Berglund s career PPG is 0.50/game, and Mr. Brassard s career PPG is 0.55/game are very similar. Mr. Berglund s season high point total is 52 in the season, while Mr. Brassard s season high point total is 45 in last year's season. Last season, both players has a similar ice time average; Mr. Brassard with 15:41 minutes at even strength and 2:31 minutes on the PP, while Mr. Berglund had an average of 16:10 minutes at even strength and 1:32 on the PP. Admittedly, Mr. Brassard had more points on the power play last year with 18 points, compared to Mr. Berglund with 4 points, but Mr. Berglund also plays on the PK with an average ice time of 1:31 minutes, compared to Mr. Brassard with 1 second 9. Mr. Berglund has also demonstrated more defensive qualities than Mr. Brassard, as shown by their plus minus ratio. Indeed, Mr. Brassard, over the course of his career, has a plus minus ratio of -37 while Mr. Berglund has a plus minus ratio of +23 in his career 10. Mr. Berglund re-signed an extension with the blues at the end of last season. The contract is worth $11.1 Million for 3 years, with a cap hit of $3.7 Million/year. 11 Both players have similar statistics offensively but defensively, Patrick Berglund is a more valuable team player. The $1.3 million that separates both players is absolutely unreasonable to justify an award greater than $3.9 Million Ibid 10 Ibid

8 B. Max Pacioretty (Montreal Canadiens) Max Pacioretty is a 25 year-old, first line LW, playing with the Montreal Canadiens 12. Mr. Pacioretty was selected 22 nd overall by the Canadiens in the 2007 NHL Entry Draft. 13 Given the fact that both players are top forwards in their respective clubs, and both are nearly of the same age and NHL experience, coupled with the notion that Mr. Pacioretty is an eligible comparable under the CBA, he is a perfect comparable for Mr. Brassard. Table : Career Statistics for Max Pacioretty SEASON TEAM GP G A P CANADIENS CANADIENS CANADIENS CANADIENS CANADIENS CANADIENS NHL TOTALS / - PPG SHG G W G Mr. Pacioretty has been in the league for 6 seasons and has played 319 games as compared to Mr. Brassard s 403 games. During the course of his career, Mr. Pacioretty has recorded 107 goals and 106 assists for a total of 213 points, while Mr. Brassard has recorded 81 goals and 144 assists for a total of 225 points. Mr. Pacioretty s career PPG 0.67/game is greatly higher than Mr. Brassard s 0.55/game career PPG. 14 Max Pacioretty s season high point total is 65, while Mr. Brassard s season high point total is 45. Furthermore, Mr. Pacioretty has 2 seasons with over 30 goals and he was on his way to have a third one during the shortened lockout season. Both players have a similar average ice time at even strength and on the power play. Moreover, last season, Mr. Pacioretty had an average ice time higher than Mr. Brassard with an average of 18:29 minutes comparatively to Mr. Brassard s average of 15:47 minutes 15. During his entire career, Mr Ibid Ibid 8

9 Pacioretty has posted better defensive statistics than Mr. Brassard. Indeed, Mr. Pacioretty has a plus minus ratio of +9 while Mr. Brassard has a plus minus ratio of In the season , Max Pacioretty re-signed with the Montreal Canadiens with a 6 year deal worth $27 million. 17 This equates to a cap hit of $4.5 Million. Given the fact that Mr. Pacioretty has better offensive and defensive statistics in every aspect, Mr. Brassard definitely deserves a salary arbitration award of $3.9 Million. C. Chris Stewart (Buffalo Sabres) Chris Stewart is a 26 year-old RW with the Buffalo Sabres. 18 Mr. Stewart was selected 18 th overall by the Colorado Avalanche, in the 2006 NHL Entry Draft. 19 Mr. Stewart has been traded twice since the beginning of his career, once in season to the St-Louis Blues, and later to the Buffalo Sabres last season. Given the fact that both players have the same offensive role within their respective club, being that both players have the same age and have been drafted in the first round in 2006, Mr. Stewart naturally serves as an interesting comparable for Mr. Brassard. SEASON TEAM GP G A P +/- PPG SHG GWG AVALANCHE AVALANCHE AVALANCHE BLUES BLUES BLUES BLUES SABRES NHL TOTALS Ibid Ibid 9

10 Mr. Stewart has been in the league for 8 seasons and has played 382 games as compared to Mr. Brassard s 403 games. During the course of his career, Mr. Stewart has recorded 115 goals and 113 assists for a total of 228 points 20. Mr. Brassard has recorded 81 goals and 144 assists for a total of 225 points. Mr. Stewart s career PPG of 0.60/game is slightly higher than Mr. Brassard s career PPG of 0.55/game. Mr. Stewart s season high point total is 64, while Mr. Brassard s season high point total is In his platform year, Mr. Brassard had a better season offensively than Mr. Stewart with 45 points compare to 26 points. However, Mr. Stewart ice time average of 13:41 was much lower than Mr. Brassard ice time average of 15:47. Notwithstanding, this notion is explainable due to the fact that the St-Louis Blues had a very strong and balanced team last year. Despite last season, both players have shown very similar offensive stats. Furthermore, both players have struggled defensively, with a poor plus minus ratio. During his career, Mr. Stewart had a ratio of 19 while Mr. Brassard had a -37 ratio, which is almost double that of Mr. Stewart's. At the end of the of season, Chris Stewart avoided arbitration and re-signed a contract extension with the St-Louis Blues. The contract is worth $8.3 million for 2 years, with a cap hit of $4.15 Million/year 22. Even if their offensive and defensive statistics are very similar during the course of their career, Mr. Stewart has the edge on Mr. Brassard with a better ratio of plus minus and a better PPG. Given these statistics, Mr. Brassard deserves a salary award of $3.9 Million. 20 Ibid 21 Ibid