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

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Table of Contents I. Introduction and Request for Hearing Decision... 2 Chart 1.1 Comparable Player Salaries... 3 II. Player Profile... 3 III. Failure to Improve On-Ice Discipline... 4 Penalty Minutes Per Game... 4 Chart. 3.1 Overall Player Improvement until Platform Year (PIMs Per Game)... 4 IV. Physicality... 5 Hits... 5 Chart 4.1 Overall Player Improvement until Platform Year (Hits Per Game)... 5 V. Failure to Distinguish Defensive Performance from Comparable Players... 6 Blocked Shots... 6 Chart 5.1 Blocked Shots in Platform Year... 7 Chart. 5.2 Giveaways and Takeaways in Platform Year... 7 VI. Lacklustre Offensive Production Given Increased Special Teams Opportunities... 8 Chart 6.1 Goals, Assists and Points in Platform Year... 9 VII. Age and Potential... 9 VIII. Conclusion... 10 1

"# Introduction and Request for Hearing Decision 1. This brief analyzes the assets and contributions of defenceman Kyle Quincey (the Player or Mr. Quincey ) to be reflected in his contract for the 2012-2013 National Hockey League ( NHL ) season. This arbitration hearing is governed by the NHL Collective Bargaining Agreement ( CBA ). Article 12.9(g)(ii)-(iii) of the CBA governs the scope of permissible information in an arbitration hearing. This includes (a) overall performance, including official statistics, (b) the number of games played by the Player, his injuries or illnesses during preceding seasons, (c) the length of service of the Player in the League and/or with the Club, (d) the overall contribution of the Player to the competitive success or failure of his Club in the preceding season, (e) any special qualities of leadership or public appeal, (f) the overall performance in the previous season or seasons of any Player(s) who is alleged to be comparable to the party Player whose salary is in dispute and (g) the compensation of any Player(s) who is alleged to be comparable to the party Player in manner consistent with the rules. 2. Additionally, in line with competition rules, the sources of information in this brief will also (1) include performance statistics obtained from credible sources of information and (2) other statistics and non-statistical information from any nationally available new materials. 3. The Detroit Red Wings request that this panel value Mr. Quincey at $3.5 million USD/year. Factors influencing our valuation of Mr. Quincey at that salary are (1) his inability to improve his on-ice discipline, (2) more valuable physicality, (3) his overall similarity in defensive characteristics, (4) his lacklustre offensive production given his elevated power play time and (5) his age and potential. 2

4. For each of the above reasons, we feel that Mr. Quincey has failed to outshine, for various reasons comparable players such as Erik Johnson, Jeff Petry and Andrej Sekera. As each of these players earn less, in some cases considerably less, than Mr. Quincey s midpoint salary, we strongly believe that Mr. Quincey s compensation should be no more than $3.5 million USD/year. Chart 1.1 Comparable Player Salaries 1 Player Salary (average dollars per year) Kyle Quincey Asking 3.775M + 1$ Erik Johnson 3.750M Jeff Petry 1.75M Andrej 2.75M Sekera 5. The following sections will analyze each of the above stated factors in our valuation of Mr. Quincey in a more detailed fashion. II. Player Profile 6. The Red Wings agree with general perspectives on Mr. Quincey as a defensive defenceman and a special teams player. As a defensive player who we needed on the ice to contain opposing forces, we view Mr. Quincey s primary relevant statistics as penalty minutes per game, hits per game, points per game and power play points. Additionally, we must address the issue of Mr. Quincey s age in relation to his comparables. 1 Found on the respective player s profile on http://capgeek.com 3

III. Failure to Improve On-Ice Discipline Penalty Minutes Per Game 7. Simply put, Mr. Quincey is often an unreliable player due to his propensity for taking too many penalties. In fact, Mr. Quincey ranked eighth in the NHL amongst defencemen in penalty minutes. 2 As is obvious, it is difficult for any player to be strong defensive presence when one is in the penalty. 8. In relation with comparable players, Mr. Quincey has had issues with total penalty minutes throughout his career and he seems either unable or unwilling to improve upon this aspect of the game. The following chart illustrates his penalty-taking propensity. Chart. 3.1 Overall Player Improvement until Platform Year (PIMs Per Game) 3 Player 2007-08 2008-09 2009-10 2010-11 2011-12 Kyle Quincey 0.67 0.86 0.96 0.86 1.24 Erik Johnson 0.41 Inj. 1.00 0.73 0.36 Jeff Petry N/A N/A N/A 0.29 0.36 Andrej Sekera 0.43 0.32 0.12 0.45 N/A 9. In comparison to every other comparable player Mr. Quincey is penalized significantly more. Compared to Mr. Johnson and Mr. Petry, he averaged nearly four times as many penalty minutes per game in his platform year. More strikingly, compared to Mr. Sekera, Mr. Quincey averaged nearly four times as many penalty minutes per game. 10. More disconcertingly from a team standpoint, Mr. Quincey s penalty minute per game rate has increased every year as a professional NHL player. In fact, for the first time since his 2 Defenceman PIM rankings found on www.nhl.com 3 Calculated based on player penalty minutes and games played found on www.nhl.com 4

rookie season, Mr. Quincey crossed the threshold of one minute of penalties per game in his platform year. While certainly some of this increase is due to the increased ice time Mr. Quincey has experienced during his growth as a professional, the fact remains that Mr. Quincey has not simply managed, at best, to improve upon his discipline in the five years he has been an NHL player. IV. Physicality Hits 11. As a defensive defenceman, Mr. Quincey is relied upon by the Red Wings to provide a physical edge and impose his will on the game. A good measure of physicality is hits. In per game terms, Mr. Quincey s production in this important physical metric is falling. As evidenced in the charts below, Mr. Quincey has declined as a hitter since his initial two seasons and stagnated for the past three. Chart 4.1 Overall Player Improvement until Platform Year (Hits Per Game) 4 Player 2007-08 2008-09 2009-10 2010-11 2011-12 Kyle Quincey 2.00 1.61 1.46 1.33 1.40 Erik Johnson 1.26 Inj. 0.89 1.29 1.69 Jeff Petry N/A N/A N/A 1.37 1.79 Andrej Sekera 0.51 0.93 0.88 0.80 N/A 12. By contrast, Mr. Johnson and Mr. Petry have enjoyed increases in hits per game from their rookie season thereby demonstrating a marked improvement in their commitments to the physical aspects of their games. 4 Calculated based on player hit totals and games played found on www.nhl.com 5

13. Even Mr. Sekera, who appears to have stagnated as a hitter in terms of hits per game, has shown a marked increase in hits per game from his rookie season a claim that Mr. Quincey cannot make. 13. This decline in hits per game is especially disappointing given the fact that Mr. Quincey, as noted in Section III, has a propensity for taking penalties at a significantly higher rate than his comparable counterparts. This suggests that Mr. Quincey s talent for drawing penalties does not arise from any borderline tough, physical checking but rather from penalties resulting from mental errors such as tripping and holding. On the whole, this diminished his value as an effective physical player in relation to his comparables. V. Failure to Distinguish Defensive Performance from Comparable Players 14. In addition to Mr. Quincey s lack of on-ice discipline and his decline in effective physicality, he has also failed to separate himself clearly from his comparable players when it comes to defensive performance as evidenced by his statistics in blocks, giveaways and takeaways. Blocked Shots 15. Blocked shots are an important measure of defensive play for a defensive defenceman because they indicate how often a defensive player was in correct position to deflect shots on goals from opposing players and because it indicates a willing to sacrifice the body in order to help the team cause. 16. Mr. Quincey enjoyed 94 blocked shots in his platform year. That is far lower than a comparable player in Mr. Petry who had 126 blocked shots in his platform year and equal to that 6

of Mr. Johnson who had also blocked 94 shots his platform year. The only comparable player who failed to block a century a shots was Mr. Sekera who still within 10 blocked shots of Mr. Quincey. Chart 5.1 Blocked Shots in Platform Year 5 Player GP BkS Kyle Quincey (2011-12) 72 94 Erik Johnson (2011-12) 73 94 Jeff Petry (2011-12) 73 126 Andrej Sekera (2010-11) 76 85 Chart. 5.2 Giveaways and Takeaways in Platform Year 6 Player GP GvA TkA Diff. Kyle Quincey (2011-72 35 24-9 12) Erik Johnson (2011-73 44 35-9 12) Jeff Petry (2011-12) 73 89 36-53 Andrej Sekera (2010-11) 76 51 38-13 17. In addition to Mr. Quincey s failure to separate himself as a defensive defenceman from comparable players in terms of the defensive measure of blocked shots, he also failed to clearly separate himself in terms of both creating and ensuring against turnovers. Success in guarding the puck is measured by giveaways and creating turnovers is measured in takeaways. 5 Blocks and Games Played were found on the respective player profiles on www.nhl.com 6 Games Played, Giveaways, Takeaways, and Assists were found on the respective player profiles on www.nhl.com 7

18. For a defensive defenceman, controlling over the puck is key. Bad turnovers in the form of giveaways generally result in scoring chances for the other team and also negatively impact the ability of the player s team to control possession and implement offensive schemes. Mr. Quincey did a good job in that respect compared to comparable players. 19. However, for a defensive defenceman like Mr. Quincey, generating turnovers is equally as important as it breaks up the opposing teams offensive rhythm and allows teammates to turn up the ice and generate scoring chances on the counter attack. In this regard, Mr. Quincey was simply the worst of the three comparable players identified in his platform year. In fact, he was the only player to fail to break the 30 takeaway mark. 20. When taken together, we can see that Mr. Quincey has failed to prove that he is markedly better at controlling the puck than his peers. Mr. Quincey is tied with Mr. Johnson and roughly equivalent to Mr. Sekera when it comes to the difference between giveaways and takeaways. In fact, Mr. Quincey only outshines Mr. Petry in this regard. 21. However, salaries must be taken into account at this point. As noted in Chart 1.1, while it is true that Mr. Quincey outshines Mr. Petry in terms of giveaways and takeaways ratio, Mr. Quincey is asking for approximately $2 million USD/year more than Mr. Petry. Meanwhile, more direct comparables in terms of giveaways and takeaways in Mr. Sekera and Mr. Johnson also earn less than Mr. Quincey s midpoint, with Mr. Sekera earning more than $1 million USD/year less than Mr. Quincey s midpoint. VI. Lacklustre Offensive Production Given Increased Special Teams Opportunities 22. The team acknowledges that, as a defensive defenceman, Mr. Quincey s primary contribution should be on the defensive end. As we have demonstrated above, we have several 8

legitimate concerns regarding Mr. Quincey s valuation significantly above that of comparable players such as Mr. Petry, Mr. Sekera and Mr. Johnson. 28. However, we must also entertain the possibility that Mr. Quincey s contributions on the offensive end merit a premium salary. In order to adjudge that possibility, we point to the total points generated by the comparable players in their platform years. Chart 6.1 Goals, Assists, Points, Time On Ice, and Power Play Time on Ice in Platform Year 7 Player GP G A P TOI PPTOI Kyle Quincey (2011-12) Erik Johnson (2011-12) Jeff Petry (2011-12) Andrej Sekera (2010-11) 72 7 19 26 21:45 2:21 73 4 22 26 20:50 2:19 73 2 23 25 21:45 1:16 76 3 26 29 21:05 2:05 29. As is evident, Mr. Quincey s offensive numbers are no better than that of his comparable players. This is especially remarkable given that Mr. Quincey leads this group in both minutes per game played and power play minutes per game played. As such, the Red Wings strongly feel that Mr. Quincey s offensive skills do not help his case when it comes to determining his salary for the 2012-2013 NHL season. VII. Age and Potential.30. A final consideration is that Mr. Quincey is 27 years old. 8 As such, Mr. Quincey may be considered to have already entered his prime years as an NHL defenceman. In comparison, 7 Goals, Assists, Points, Time On Ice, and Power Play Time statistics were found on the respective player profiles on www.nhl.com 9

every other comparable player at the time of signing his contract was below the age of 25. This means that they had additional time to fulfill their potential as NHL players. VIII. Conclusion 31. Mr. Quincey is a fine player and the Red Wings wish to keep him as a member of the team. However, this must be done at a price which is borne out by market factors. According to the factors identified in the NHL CBA, Mr. Quincey clearly merits less than his stated midpoint salary. As shown above, Mr. Quincey still has a considerable ways to go before being as disciplined as his comparable players, his effective physicality may be on the decline, his defensive statistics do not demonstrate that he is better than his comparable players, his offensive statistics are at best comparable to his peers and he has arguably less room for potential growth given his advanced age in relation to the others. 32. Therefore, the question must be asked is is Mr. Quincey worth roughly $2 million USD/year more than Mr. Petry, $1 million USD/year more than Mr. Sekera and more than Mr. Johnson? The answer appears to be no. 8 Found on Kyle Quincey s player profile on www.nhl.com 10