IN THE MATTER OF A SALARY ARBITRATION BETWEEN: CARL GUNNARSSON - AND - THE TORONTO MAPLE LEAFS BRIEF IN SUPPORT OF THE TORONTO MAPLE LEAFS HOCKEY CLUB

Similar documents
IN THE MATTER OF SALARY ARBITRATION CARL GUNNARSSON AND THE TORONTO MAPLE LEAFS

2013 HOCKEY ARBITRATION COMPETITION OF CANADA. Carl Gunnarsson v. Toronto Maple Leafs. Submission on Behalf of the Player. Midpoint: $3.

~ BRIEF IN SUPPORT OF CARL GUNNARSSON ~ IN THE MATTER OF SALARY ARBITRATION BETWEEN: CARL GUNNARSSON AND THE TORONTO MAPLE LEAFS

2013 Hockey Arbitration Competition of Canada

2013 Hockey Arbitration Competition of Canada. Carl Gunnarsson v Toronto Maple Leafs Submission on Behalf of Carl Gunnarsson Submission by Team 24

Team 10. Carl Gunnarsson. Club Side

2014 Hockey Arbitration Competition of Canada. Lars Eller v. The Montreal Canadiens. Team 10. Submission on Behalf of Lars Eller

Table of Contents I. Introduction and Request for Hearing Decision... 2 Chart 1.1 Comparable Player Salaries... 3 II. Player Profile... 3 III.

CARL GUNNARSSON THE TORONTO MAPLE LEAFS

2012 Hockey Arbitration Competition of Canada

2013 HOCKEY ARBITRATION COMPETITION OF CANADA. Mats Zuccarello v. The New York Rangers. Submission on Behalf of Mats Zuccarello. Midpoint: $1.

2013 HOCKEY ARBITRATION COMPETITION OF CANADA

Team 10 Mats Zuccarello Club Side

IN THE MATTER OF SALARY ARBITRATION BETWEEN: CODY FRANSON -AND- THE TORONTO MAPLE LEAFS

In the Matter of Salary Arbitration Between: Cody Franson. -And- Toronto Maple Leafs. Brief of: Toronto Maple Leafs (Club) Team 31

IN THE MATTER OF SALARY ARBITRATION BETWEEN: CODY FRANSON -AND- THE TORONTO MAPLE LEAFS BRIEF ON BEHALF OF THE PLAYER CODY FRANSON TEAM 3

2014 Hockey Arbitration Competition of Canada

2012 Hockey Arbitration Competition of Canada

HOCKEY ARBITRATION COMPETITION OF CANADA

IN THE MATTER OF AN ARTICLE 12 SALARY ARBITRATION PURSUANT TO THE NATIONAL HOCKEY LEAGUE S COLLECTIVE BARGAINING AGREMEENT MATS ZUCCARELLO -AND-

Team 1. Cody Franson vs. Toronto Maple Leafs. Submission on behalf of Cody Franson (Player Side)

2013 Hockey Arbitration Competition of Canada

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

IN THE MATTER OF SALARY ARBITRATION BETWEEN: CARL GUNNARSSON -AND- THE TORONTO MAPLE LEAFS BRIEF OF THE TORONTO MAPLE LEAFS TEAM 32

NHL SALARY ARBITRATION CHRIS STEWART AND THE ST. LOUIS BLUES BRIEF IN SUPPORT OF CHRIS STEWART

TEAM 12. Case 1: SAM GAGNER. Acting for PLAYER

HOCKEY ARBITRATION COMPETITION OF CANADA

IN THE MATTER OF A SALARY ARBITRATION LARS ELLER -AND- MONTREAL CANADIENS NATIONAL ACADEMY OF ARBITRATORS

2013 HOCKEY ARBITRATION COMPETITION OF CANADA

SALARY ARBITRATION BETWEEN CODY FRANSON AND THE TORONTO MAPLE LEAFS BRIEF FOR CODY FRANSON TEAM 17

Mats Zuccarello-Aasen v. New York Rangers. Team 4. Representing: the Player

IN THE MATTER OF SALARY ARBITRATION BETWEEN: LARS FOSGAARD ELLER. - and - THE MONTREAL CANADIENS BRIEF OF LARS FOSGAARD ELLER TEAM 19

2013 HOCKEY ARBITRATION COMPETITION OF CANADA. Chris Stewart v St. Louis Blues (NHL) SUBMISSION ON BEHALF OF CHRIS STEWART TEAM #14

IN THE MATTER OF SALARY ARBITRATION BETWEEN: CODY FRANSON -AND- THE TORONTO MAPLE LEAFS SUBMISSION OF BEHALF OF THE TORONTO MAPLE LEAFS TEAM 28

Team Number 25 Case: Cody Franson Club s Representative

IN THE MATTER OF SALARY ARBITRATION BETWEEN: CODY FRANSON -AND- THE TORONTO MAPLE LEAFS SUBMISSION ON BEHALF OF CODY FRANSON TEAM 21

IN THE MATTER OF SALARY ARBITRATION BETWEEN: CODY FRANSON. - and - THE TORONTO MAPLE LEAFS BRIEF OF CODY FRANSON TEAM 19

2014 National Baseball Arbitration Competition

HOCKEY ARBITRATION COMPETITION OF CANADA

IN THE MATTER OF SALARY ARBITRATION BETWEEN: LARS ELLER -AND- THE MONTREAL CANADIENS BRIEF OF THE MONTREAL CANADIENS. Team 27

HOCKEY ARBITRATION COMPETITION OF CANADA IN THE MATTER OF SALARY ARBITRATION BETWEEN DERRICK BRASSARD - AND - THE NEW YORK RANGERS

2014 NATIONAL BASEBALL ARBITRATION COMPETITION ERIC HOSMER V. KANSAS CITY ROYALS (MLB) SUBMISSION ON BEHALF OF THE CLUB KANSAS CITY ROYALS

IN THE MATTER OF SALARY ARBITRATION BETWEEN: DERICK BRASSARD - AND - THE NEW YORK RANGERS HOCKEY CLUB BRIEF IN SUPPORT OF DERICK BRASSARD (TEAM 8)

2015 NATIONAL BASEBALL ARBITRATION COMPETITION

Team 9 IN THE MATTER OF A SALARY ARBITRATION BETWEEN: SAM GAGNER. (The Player ) and THE EDMONTON OILERS. (The Club ) THE PLAYER S BRIEF

2014 Tulane Baseball Arbitration Competition Josh Reddick v. Oakland Athletics (MLB)

2015 NATIONAL BASEBALL ARBITRATION COMPETITION. Mark Trumbo v. Arizona Diamondbacks. Submission on Behalf of Mark Trumbo. Midpoint: $5,900,000

2013 National Baseball Arbitration Competition

Lars Eller v. Montreal Canadiens

2014 Tulane Baseball Arbitration Competition Eric Hosmer v. Kansas City Royals (MLB)

2015 National Baseball Arbitration Competition

IN THE MATTER OF SALARY ARBITRATION BETWEEN: LARS ELLER -AND- THE MONTREAL CANADIENS SUBMISSION ON BEHALF OF LARS ELLER TEAM 21

IN THE MATTER OF SALARY ARBITRATION BETWEEN: LARS ELLER - AND - THE MONTREAL CANADIENS BRIEF IN SUPPORT OF THE MONTREAL CANADIANS HOCKEY CLUB (TEAM 8)

Dexter Fowler v. Colorado Rockies (MLB)

TULANE BASEBALL ARBITRATION COMPETITION. Isaac Benjamin Davis. New York Metropolitan Baseball Club, Inc. ARBITRATION BRIEF FOR ISAAC BENJAMIN DAVIS

2015 National Baseball Arbitration Competition

Team 1. Lars Eller vs. Montreal Canadiens. Submissions on behalf of Montreal Canadiens (Team Side)

In the Matter of Salary Arbitration Between: Cody Franson -AND- The Toronto Maple Leafs. Team 9. Submission of the Toronto Maple Leafs

Lorenzo Cain v. Kansas City Royals. Submission on Behalf of the Kansas City Royals. Team 14

2013 Tulane National Baseball Arbitration Competition

Team Number 6. Tommy Hanson v. Atlanta Braves. Side represented: Atlanta Braves

2014 National Baseball Arbitration Competition

2014 Tulane National Baseball Arbitration Competition Jeff Samardzija v. Chicago Cubs (MLB)

Jenrry Mejia v. New York Mets Submission on Behalf of New York Mets Midpoint: $2.6 Million Submission by Team 18

2014 NATIONAL BASEBALL ARBITRATION COMPETITION

Dexter Fowler v. Colorado Rockies. Submission on Behalf of the Colorado Rockies. Team 18

Team Number 25 Case: Lars Eller Club s Representative

2014 National Baseball Arbitration Competition

2014 National Baseball Arbitration Competition

JEFF SAMARDZIJA CHICAGO CUBS BRIEF FOR THE CHICAGO CUBS TEAM 4

In the Matter of Salary Arbitration Between: Lars Eller -AND- The Montreal Canadiens. Team 9. Submission of Lars Eller

Detroit Red Wings Clips August 23-25, 2014

TULANE UNIVERISTY BASEBALL ARBITRATION COMPETITION NELSON CRUZ V. TEXAS RANGERS BRIEF FOR THE TEXAS RANGERS TEAM # 13 SPRING 2012

Jenrry Mejia v. New York Mets Submission on Behalf of the New York Mets Midpoint: $2.6M Submission by Team 32

Detroit Red Wings Clips August 14, 2014

2014 Tulane Baseball Arbitration Competition Eric Hosmer v. Kansas City Royals

2013 National Baseball Arbitration Competition Tulane University Law School

2013 National Baseball Arbitration Competition. Tommy Hanson v. Atlanta Braves. Submission on behalf of Atlanta Braves. Submitted by Team 28

Club: Carolina Hurricanes, NHL Latest Swedish club: Brynäs IF First club: Norrtälje IK Sweden games: 3 A, 0 B, 10 junior games

NHL SALARY DETERMINATION AND DISTRIBUTION A THESIS. Presented to. The Colorado College. Bachelor of Arts. Ian Young. February 2015

News in Review February 2013 Teacher Resource Guide HOCKEY LOCKOUT: A Season Saved

Salary Arbitration, A Burden or a Benefit. By Bill Gilbert SABR 36. Seattle, Washington. June 29, 2006

2015 NATIONAL BASEBALL ARBITRATION COMPETITION

Club: Carolina Hurricanes, NHL Latest Swedish club: Brynäs IF First club: Norrtälje IK Sweden games: 0 A, 0 B, 10 junior games

Detroit Red Wings Clips August 26, 2016

Team 10. Texas Rangers v. Nelson Cruz. Brief in support of Nelson Cruz

SPORT DISPUTE RESOLUTION CENTRE OF CANADA (SDRCC) AND AND DECISION

2010 U.S. Olympic Men s Ice Hockey Player Stats All-Time Team USA Stats & NHL Stats NHL stats through Dec. 31 games

2015 National Baseball Arbitration Competition

The Puck Stops Here: Analysis of Salary Arbitration in the National Hockey League

TULANE NATIONAL BASEBALL ARBITRATION COMPETITION 2012 NELSON CRUZ, PLAYER TEXAS RANGERS, TEAM BRIEF FOR TEXAS RANGERS, TEAM. Team no.

to the Kansas City Royals for the purposes of an arbitration hearing governed by the Major

Elite Spring Teams Edition Overview

HOW DO ENTRY-LEVEL CONTRACTS WORK?

BAY ST. OFFICIAL DRAFTBOOK 2019 HHTH BAY ST. DRAFT NIGHT DRAFT NIGHT PRESENTED BY

Detroit Red Wings Clips Aug. 4, 2015

Paul M. Sommers And Justin R. Gaines. March 2010 MIDDLEBURY COLLEGE ECONOMICS DISCUSSION PAPER NO

2015 NATIONAL BASEBALL ARBITRATION COMPETITION. Lorenzo Cain v. Kansas City Royals (MLB) SUBMISSION ON BEHALF OF KANSAS CITY ROYALS BASEBALL CLUB

GOALKEEPERS. 1. FELIX SANDSTRÖM Born: Gävle Jan Length: 187 cm Weight: 84 kg

The Penguins will relinquish their rights to two prospects, center Andy Bathgate and defenseman Viktor Ekbom.

Transcription:

IN THE MATTER OF A SALARY ARBITRATION BETWEEN: CARL GUNNARSSON - AND - THE TORONTO MAPLE LEAFS BRIEF IN SUPPORT OF THE TORONTO MAPLE LEAFS HOCKEY CLUB TEAM 26

Table of Contents I. INTRODUCTION A. Club Position..... 2 B. Player Introduction. 3 1. Gunnarsson s Early Years... 4 2. Gunnarsson s Platform Year... 5 C. Intangibles.. 5 II. COMPARABLE PLAYERS A. Selection of Comparable Players... 6 B. Comparable Player Essentials.... 6 C. Carl Gunnarsson v. Comparable Players... 7 i. Carl Gunnarsson v Zach Bogosian.. 7 ii. Carl Gunnarsson v Anton Stralman... 7 iii. Carl Gunnarsson v Kyle Quincey. 8 iv. Carl Gunnarsson v Andrej Sekera 8 III. CONCLUSION... 9 1

I. INTRODUCTION This brief analyzes the past performance and contributions of defenseman Carl Gunnarsson ( Gunnarsson or the Player ) and the Toronto Maple Leafs Hockey Club (the Leafs or the Club ) of the National Hockey League ( NHL ). This matter is pursuant to Article 12 of the 2012 Collective Bargaining Agreement (the CBA ), between the NHL and the National Hockey League Players Association (the NHLPA ). In accordance with the CBA, the evidence to be considered in determining the player s salary arbitration award includes: the overall performance of the Player in all seasons; the number of games played by the Player and his injuries or illnesses in all seasons; the length of service of the Player; the overall contribution of the Player to the competitive success of the Club in the preceding season; any special qualities of leadership or public appeal; the overall performance of players alleged to be comparable to the Player whose salary is in dispute; and the compensation of players alleged to be comparable to the Player whose salary is in dispute. 1 A. CLUB POSITION This brief will consider the essential criteria in turn. Mr. Carl Gunnarsson is a valued member of the Leafs organization, and it is in the interests of the club to keep the player with the team in future. With respect to Gunnarsson s statistics from his platform year ( PY ) (the 2012-13 season) and his career performance, it is the Leafs position that the appropriate average annual value ( AAV ) for Gunnarsson s contract for 2013-14 is less than the $3.15 million midpoint figure. The Club respectfully requests that the panel find that he is entitled to a salary arbitration award of $3,149,999, as the Club believes that this is an appropriate and fair value for the Player with respect to the NHL marketplace for defensemen. B. PLAYER INTRODUCTION 1 Articticle 12.1, National Hockey League and National Hockey League Players Association, Collective Bargaining 2

Mr. Carl Gunnarsson is a 26 year old defenceman who has accumulated 224 games in four seasons with the Leafs. The Leafs originally drafted Gunnarsson as the 194 th pick in the 7 th round of the 2007 NHL entry draft. Gunnarsson stands 6 2, weighs 196 pounds, and was born in Orebro, Sweden. 2 Considered to have the career potential of a stabilizing big minute defenseman, Gunnarsson is an asset due to his excellent frame and long reach, ability to move the puck quickly and efficiently out of danger, and ability to serve in a shutdown or limited power play role. 3 However, Gunnarson is limited as a big minute defenseman due to his inability to adopt a physical game, his alleged lack of strength, and overall lack of production. 4 The on-ice characteristics that Gunnarsson brings to the Leafs are as follows: v Experience: As a relatively young defenseman, with respect to the typical retirement age of established NHL defenseman 5, Gunnarsson should be a reliable defenseman in the league for seasons to come. Gunnarsson has already accumulated 224 games in his 4 year career, and has played significant minutes alongside Dion Phaneuf as Toronto s top defensive pairing. The efficient and defensive style of Gunnarsson make him an ideal partner for offensive minded defensemen, and he has demonstrated the potential to continue to contribute to the Club s defense. v Durability: Throughout the Player s career there has been an absence of recurring injuries. However, Gunnarsson has yet to play a full 82 game season, as he has missed games due to: a hyper-extended elbow (missed 22 games in 2009-10); hand, ankle and shoulder injuries (missed 5 games in 2010-11); and a hip injury (missed 11 games in 2012-13). 6 2 http://www.nhl.com/ice/player.htm?id=8474125 3 http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5218 4 Ibid note 3 5 http://www.quanthockey.com/distributions/retireeagedistribution.php 6 http://www.tsn.ca/nhl/teams/players/bio/?id=5218 3

v Consistency: Gunnarsson s performance has been relatively consistent with respect to points, as he has averaged between.25 and.41 points per game ( P/GP ). Contributions with respect to goals per game ( G/GP ) has trended down from.07 to.03, while assists per game ( A/GP ) have been anywhere in the range of.20 to.41. Gunnarsson has averaged over 21 minutes per game in three of his four seasons with the Club, and has split his career with two plus and two minus seasons. 7 While his defensive efforts may be called into question due to his plus-minus ( +/- ) statistics, three of the four seasons saw the Club ice a team that was far from playoff contention. CARL GUNNARSSON S NHL CAREER STATISTICS (2009-2013) GP G A PTS +/- PIM S 2012-13 37 1 14 15 5 14 28 2011-12 76 4 15 19-9 20 89 2010-11 68 4 16 20-2 14 69 2009-10 43 3 12 15 8 10 45 CARL GUNNARSSON S NHL CAREER STATISTICS: OTHER (2009-2013) G/GP A/GP P/GP H BKS GvA TkA EV PP SH AVG 2012-13.03.38.41 78 71 32 11 17:55 :45 2:35 21:16 2011-12.05.20.25 114 152 65 34 17:50 1:12 2:38 21:42 2010-11.06.24.29 63 120 44 24 14:17 1:20 2:36 18:14 2009-10.07.28.35 46 77 36 8 16:48 1:51 2:46 21:26 1. GUNNARSSON S EARLY YEARS Following 4 years of development with Linkoping of the Swedish Elite League, Gunnarsson quickly transitioned to the NHL, playing only briefly with Toronto s AHL affiliate (12 games), before being called up by the Club where he has played since. Playing in 43 games as a rookie with the Club, Gunnarsson scored 3 goals and added 12 assists. In the following two seasons Gunnarsson s production leveled off as he contributed 20 points (4 G, 16 A) in 68 games played in 2010-11, and 19 points (4 G, 15 A) in 76 games played in 2011-12. Gunnarsson 7 http://www.nhl.com/ice/player.htm?id=8474125&view=splits 4

established himself as a reliable defenseman that could contribute on occasion, but was primarily relied upon to play the harder minutes against the opposition s top lines and on the penalty kill. 2. GUNNARSSON S PLATFORM YEAR In his PY, Gunnarson produced consistently with respect to his career averages, as he accumulated 15 points (1 G, 14 A) in 37 games in the lock-out shortened season. Gunnarsson s average G/GP (.03) declined, but his A/GP (.38) were at a career high. Gunnarsson finished +5 on the season, ranked second amongst the Club s defensemen, and tied for 49 th amongst all defensemen, and played an average of 21:16 per game, ranked 3 rd on the Club, and 78 th in the league. 8 While Gunnarsson s production has remained quite consistent, it is unclear if Gunnarsson s offensive output is linked to the production of his current partner Phaneuf, nor is it clear whether his point production is trending up or down in future. It is clear, however, that Gunnarsson offers a reliable top defensive pairing when alongside Phaneuf, 9 and consistent minutes on the Leafs penalty kill, which ranked 2 nd in the NHL in 2012-13. 10 C. INTANGIBLES Gunnarsson does not currently serve as a captain or alternate captain for the Club, but his duration of service with the team is noteworthy (currently one of five members remaining with the team since the 2009 season). 11 Gunnarsson participates in the community programs hosted by the Leafs, including the Annual Visit to Sick Kids Hospital, 12 A Night with Blue & White, and 8http://www.nhl.com/ice/playerstats.htm?season=20122013&gameType=2&team=&position=D&country=& status=&viewname=summary 9 http://www.defendingbigd.com/2013/5/6/4283942/dallas- stars- 2013- nhl- phaneuf- gunnarsson- bouwmeester- michalek- giordano 10 http://espn.go.com/nhl/statistics/team/_/stat/special- teams/sort/penaltykillpct 11 http://www.tsn.ca/toronto/blogs/jonas_siegel/?id=432377 12 http://mapleleafs.nhl.com/club/page.htm?id=62155 5

the Leafs & Legends Charity Golf Classic. 13 However, Gunnarsson has not adopted a substantial role in the community outside of what is required by the team. II. COMPARABLE PLAYERS A. SELECTION OF COMPARABLE PLAYERS In selecting comparable players, the Club considered similarly productive defensemen with comparable ice time who were arbitration-eligible in the summer of 2011, 2012, or 2013. The comparable players submitted at the outset are Zach Bogosian, Anton Stralman, Kyle Quincey, and Andrej Sekera. This brief will demonstrate that the most comparable players are: Stralman, Quincey, and Sekera. B. COMPARABLE PLAYER ESSENTIALS CONTRACTUAL BACKGROUND 14 Player Age Team Date Signed Contract Year New Contract AAV Carl Gunnarsson 26 Toronto Unknown 1,325,000 Unknown Unknown Zach Bogosian 23 Winnipeg July 2013 2,500,000 5,142,857 5,142,857 Anton Stralman 26 New July 2012 900,000 1,700,000 1,700,000 York Kyle Quincey 27 Detroit July 2012 3,125,000 3,775,000 3,775,000 Andrej Sekera 25 Buffalo July 2011 1,000,000 2,750,000 2,750,000 CAREER TO PLATFORM YEAR STATISTICS Player GP G A PTS +/- PIM S Carl Gunnarsson 224 12 57 69 2 58 231 Zach Bogosian 297 34 69 103-42 237 635 Anton Stralman 265 13 79 92-31 117 339 Kyle Quincey 257 18 77 95-5 250 509 Andrej Sekera 233 12 55 67 5 80 259 PLATFORM YEAR STATISTICS Player GP G A PTS +/- PIM S Carl Gunnarsson 37 1 14 15 5 14 28 Zach Bogosian 33 5 9 14-5 29 85 Anton Stralman 53 2 16 18 9 20 55 Kyle Quincey 72 7 19 26-1 89 168 13 http://www.mlsefoundation.org/events 14 http://capgeek.com/ 6

Andrej Sekera 76 3 26 29 11 34 88 PLATFORM YEAR STATISTICS: OTHER Player G/ GP A/ GP PTS/ GP H BKS GvA TkA EV PP SH AVG Carl Gunnarsson.03.38.41 78 71 32 11 17:55 :45 2:35 21:16 Zach Bogosian.15.27.42 79 50 28 12 19:23 1:44 1:59 23:07 Anton Stralman.04.30.34 76 71 12 11 15:16 1:12 :36 17:05 Kyle Quincey.07.28.35 46 77 36 8 16:48 1:51 2:46 21:26 Andrej Sekera.04.34.38 61 85 51 38 17:11 2:05 1:49 21:05 C. CARL GUNNARSSON V. COMPARABLE PLAYERS i. CARL GUNNARSSON V. ZACH BOGOSIAN Zach Bogosian is a 23 year old defenseman who has accumulated 297 games in five seasons with the Winnipeg Jets and Atlanta Thrashers. The Thrashers originally drafted Bogosian as the 3 rd pick in the 1 st round of the 2008 NHL entry draft. Bogosian stands 6 3, weighs 215 pounds, and was born in Massena, New York. While the P/GP of Bogosian was similar in his PY, Bogosian has consistently produced at a higher level throughout his career. With respect to the differences in age, development, and role on the team s defense, the Leafs do not believe that these players are similar enough to consider this comparison legitimate. Furthermore, the Leafs believe this comparison is minimally persuasive at most, given the length of term granted to Bogosian in his arbitration hearing. ii. CARL GUNNARSSON V ANTON STRALMAN Anton Stralman was a 26 year old defenseman who had accumulated 265 games in 5 seasons with the Leafs, Columbus Blue Jackets, and New York Rangers by his arbitrationeligible summer. The Leafs originally drafted Stralman as the 216 th pick in the 7 th round of the 2005 NHL entry draft. Stralman stands 5 11, weighs 190 pounds, and was born in Tibro, Sweden. Gunnarsson and Stralman scored similar P/GP averages in their PYs; however, Gunnarson was utilized less on the power play ( PP ), but more on the penalty kill ( PK ) and in 7

the game overall. In an additional 41 games played in his career, Stralman had accumulated 23 more points (1 G, 22A) than Gunnarsson. With respect to considerations of time on ice ( ) in the platform year, it is evident that Stralman was utilized more in an offensive role. Considering the difference in their physical characteristics and utilization by their respective teams, the Club does not feel that the players are perfectly comparable. iii. CARL GUNNARSSON V. KYLE QUINCEY Kyle Quincey was a 27 year old defenseman who had accumulated 257 games in 8 seasons with the Detroit Red Wings, Los Angeles Kings, and Colorado Avalanche. The Red Wings originally drafted Quincey as the 132 nd pick in the 4 th round of the 2003 NHL entry draft. Quincey stands 6 2, weighs 207 pounds, and was born in Kitchener, Ontario. These comparable players contributed similar P/GP their PYs; however, the two are distinguishable with respect to their roles on their respective team s defense. Quincey was utilized more often in the role of an offensive defenseman, and expected to be a contributor to the Red Wings PP. Quincey was a year older at the time the contract was signed, and his career statistics reveal a player with more offensive potential, as he contributed 26 more points (6 G, 20 A) in 33 more games. The Club also noted that the goal production of the Player is trending down, contrasted with Quincey s which was trending up in his PY. iv. CARL GUNNARSSON V. ANDREJ SEKERA Andrej Sekera was a 26 year old defenseman who had accumulated 233 games in 5 seasons with the Buffalo Sabres. The Sabres originally drafted Sekera as the 71 st pick in the 3 rd round of the 2004 NHL entry draft. Sekera stands 6 0, weighs 201 pounds, and was born in Bojnice, Slovakia. While Sekera is a less persuasive player due to his arbitration eligibility occurring outside the period of relevancy, the Club believes that this is a relevant comparison. Gunnarsson and 8

Sekera produced very similar averages in their PY, with the greatest distinguishing factor being the difference in PP time allotted to the two defensemen. The two were similarly responsible for approximately 21 minutes per night, and performed the similar role of consistent, and efficient shut down defenseman. III. CONCLUSION Although the Player has limited experience compared to the other arbitration-eligible defensemen, he has asserted similar offensive numbers throughout the course of his career. The relevant comparable defensemen are offensive defensemen, utilized by their clubs in offensive situations. The club believes that the contracts for Stralman and Quincey should be utilized to set the contract window $1,700,000 and $3,750,000. With respect to the less persuasive contract of Sekera, the market for more defensively inclined defensemen is established around $2,750,000. While Gunnarsson established similar production to that of Quincey in his platform year, Quincey has a history of being more offensive productive throughout his career, and seems to be an aberration with respect to value. The other similarly productive defensemen were all paid less than $3,000,000. The club concedes Gunnarsson value to the defense of the Maple Leafs believing that he should be paid more than the other similarly productive defensemen, but not substantially more. With respect to the factors outlined herein, the Toronto Maple Leafs Hockey Club believes that the proposed salary of $3,149,999 is fair and equitable compensation. 9