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IN THE MATTER OF A SALARY ARBITRATION BETWEEN:

K Y L E Q UIN C E Y

-AND-

T H E D E T R O I T R E D W IN GS

BRIEF IN SUPPORT OF A COMPENSATION REQUEST FOR

(CLUB-SIDE)

Ottawa Team 1

Hearing Date: October 6, 2012

T A B L E O F C O N T E N TS

I. INTRODUCTION AND OVERVIEW ...... 1 A. AN INTRODUCTION TO KYLE QUINCEY ...... 1 i. KYLE QUINCEY: THE NHL YEARS ...... 2 Overview of 2005-2011 ...... 2 2011-12: Platform Year ...... 3 II. SELECTION OF COMPARABLE PLAYERS ...... 3 III. COMPARISON BETWEEN QUINCEY AND COMPARABLE PLAYERS ...... 4 Kyle Quincey v. ...... 4 Kyle Quincey v. ...... 6 Kyle Quincey v. ...... 7 Kyle Quincey v. ...... 8 IV. CONCLUSION ...... 10

I. IN T R O DU C T I O N A ND O V E R V I E W

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forth herin, Quincey requests compensation in the amount of $3,500,000 for the 2012-13

season.

A. A N IN T R O DU C T I O N T O K Y L E Q UIN C E Y

4XLQFH\ LV D ¶´  SRXQG GHIHnceman for the . Born in Kitchener

Ontario on August 12, 1985, he is 27 years old. Quincey was drafted by the Detroit Red

Wings in the 4th round, 132nd overall, in the 2003 NHL Entry Draft. He signed his entry-level

deal with the Red Wings in 2005, re-signed as an RFA to a 2-year deal in 2008, and was

claimed off waivers by the in 2008. He then signed a 2-year RFA deal

with the Avalance who, in turn, traded him to the Red Wings in 2012.1

1 www.tsn.ca/nhl/teams/players

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i. K Y L E Q UIN C E Y: T H E N H L Y E A RS R E G U L A R SE ASO N Season GP G A PTS PIM +/- TOI PPP SOG %

2005-06 1 0 0 0 0 0 11:37 0 1 0.0 (Detroit) 2006-07 6 1 0 1 0 0 11:26 0 7 14.3 (Detroit) 2007-08 6 0 0 0 4 -3 13:58 0 5 0.0 (Detroit) 2008-09 (LA) 72 4 34 38 63 -5 20:58 27 150 2.7 2009-10 79 6 23 29 76 9 23:37 11 139 4.3 (Colorado) 2010-11 21 0 1 1 18 -5 19:35 0 39 0.0 (Colorado) 2011-12 54 5 18 23 60 -1 22:21 9 131 3.8 (Colorado) 2011-12 18 2 1 3 29 0 20:22 1 37 5.4 (Detroit) Career 257 18 77 95 250 -5 21:30 48 509 3.5 Source: www.espn.go.com/nhl/player/stats/_/id/3082/kyle-quincey

Overview of 2005-2011

After being drafted by the Red Wings in the 4th round of the 2003 Entry Draft, Quincey spent

two more seasons playing in the . After signing his 3-year entry level

contract in 2005, he spent the majority of the first 3 years of his career playing for the Red

:LQJV¶AHL affiliate. Quincey managed to get into 13 NHL games during that span. As a

member of the Los Angeles Kings, Quincey was able to establish himself in his one season

with the team. He established a career-high in assists (34), points (38), powerplay points

(PPP) (27), and shots (150). In 2009-10, as a member of the Colorado Avalance, Quincey

continued to produce, establishing career-highs in games played (GP) (79), goals (6),

minutes (PIM) (76), plus/minus (+/-) (9) and time on ice (TOI) (23:36). Quincey only

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managed to play 21 games in 2010-11, as he suffered from both a concussion and shoulder

injury. This significantly affected his output as he only managed 1 during the season.

2011-12: Platform Year

Quincey started the season in Colorado, scoring 23 points in 54 games before being traded to

Detroit at the trade deadline in February. As a member of the Avalanche, he averaged 0.43 points per game (PTS/G), while his TOI was 22:21. After being acquired by the Red Wings, he struggled to establish himself in the 18 games played, compiling 3 points, an average of 0.17

PTG/G, while is TOI decreased to 20:22. Quincey was playing top 4-5 minutes in

Detroit.

II. SE L E C T I O N O F C O MPA R A B L E PL A Y E RS

An important stage in the salary arbitration process is selecting the appropriate comparables in order to determine a just salary figure for a player. While there are many NHL defenceman who were restricted free agents over the past two off-seasons, it was a challenge finding a player with a similar career path and production to Quincey (i.e. 27 year old, drafted in 2003, signed in 2005 and having played 8 seasons in the league). The criteria used to determine comparable players included: age, games played, durability, career to platform statistics, and statistics during their platform year. The comparable players chosen include: Matt Niskanen, Marc Methot, Josh

Gorges, and Marc Staal. We have concluded that Matt Niskanen is the best comparable player to

Kyle Quincey.

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III. C O MPA RISO N B E T W E E N Q UIN C E Y A ND C O MPA R A B L E PL A Y E RS K yle Quincey v Comparable Players Career to Platform Season Statistics (Regular Season) Player GP G A PTS PTS/G PIM PIM/G +/- TOI K yle Quincey 257 18 77 95 0.37 250 0.97 -5 21:30 Matt Niskanen 370 21 86 107 0.29 203 0.55 2 18:44 Marc Methot 229 6 38 44 0.19 208 0.91 5 18:48 Josh Gorges 364 9 50 59 0.16 183 0.50 12 19:40 Marc Staal 244 13 39 52 0.21 150 0.61 6 21:53 Sources: www.nhl.com/ice/playerstats; www.hockey-reference.com

K yle Quincey v Comparable Players Platform Season Statistics (Regular Season) Player Platform GP G A PTS PTS/ PIM PIM/G +/- TOI G K yle 11-12 72 7 19 26 0.36 89 1.24 -1 21:52 Quincey Matt 11-12 75 4 17 21 0.28 47 0.63 9 17:56 Niskanen Josh Gorges 10-11 36 1 6 7 0.19 18 0.5 -3 21:10 Marc Methot 10-11 74 0 15 15 0.20 58 0.78 2 19:53 Marc Staal 09-10 82 8 19 27 0.33 44 0.54 11 23:08 Source: www.nhl.com/ice/playerstats

K yle Quincey v Comparable Players Career to Platform Playoff Statistics Player Platform GP G A PTS PTS/ PIM PIM/G +/- TOI G K yle 11-12 24 0 2 2 0.08 16 0.67 0 13:24 Quincey Matt 11-12 27 1 6 7 0.26 16 0.59 -3 15:49 Niskanen Josh Gorges 10-11 46 0 7 7 0.15 25 0.54 -7 20:45 Marc Methot 10-11 4 0 0 0 0 2 0.5 -3 19:53 Marc Staal 09-10 17 2 2 4 0.24 8 0.47 -1 21:58 Source: www.nhl/com/ice/playerstats

K yle Quincey v. Comparable Player Contracts Player Current Age Age at Signing Platform Year AAV K yle Quincy- Red Wings 27 27 2011-12 $3,500,000 Matt Niskanen- Penguins 25 25 2011-12 $2,300,000 Josh Gorges- Canadiens 28 27 2010-11 $2,500,000 Marc Methot- Senators 27 25 2010-11 $3,000,000 Marc Staal- Rangers 25 23 2009-10 $3,975,000 Source: www.capgeek.com

K yle Quincey v. Matt Niskanen

K yle Quincey v Comparable Players Platform Season Statistics (Regular Season) Player Platform GP G A PTS PTS/ PIM PIM/G +/- TOI GvA G K yle Quincey 11-12 72 7 19 26 0.36 89 1.24 -1 21:52 35 Matt Niskanen 11-12 75 4 17 21 0.28 47 0.63 9 17:56 20

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K yle Quincey v Comparable Players Career to Platform Season Statistics (Regular Season) Player GP G A PTS PTS/G PIM PIM/G +/- TOI K yle Quincey 257 18 77 95 0.37 250 0.97 -5 21:30 Matt Niskanen 370 21 86 107 0.29 203 0.55 2 18:44

1LVNDQHQLVD\HDUROG¶´SRXQGGHIHQFHPDQ with the . He signed a 2 year deal this past off-season with an AAV of $2,300,000.2 Niskanen is a good comparable to

Quincey given their similarities in terms of age, years in the NHL and platform year (2011-12).

Games Played- Niskanen has played 113 more games than Quincey to date. While two years younger than Quincey, he entered the league in 2007, playing 78 games for the and has been a regular in both the Dallas and Pittsburgh -ups since.

Durability- Niskanen has been a durable player throughout his career. Aside from the 2010-11 season, where he only managed to play in 63 games, he has never played less than 74 games in a season. Not only is he durable in terms of game played, he also has averaged 17:56 of ice time throughout his career and has never averaged less than 16:32 per season. He has been a model for consistency since he entered the league.

Career to Platform Statistics- As Niskanen has played 113 more games than Quincey, it is best to look at the points per game statistic where Niskanen has averaged 0.29 PTS/G compared to

4XLQFH\¶V Given that Quincey averages almost 3 more minutes per game, this statistic is somewhat skewed and would likely be in favour of Niskanen with more ice time. Furthermore,

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Niskanen is in the less and has more opportunity to be on the ice. Niskanen is also a

+2 player for his career, compared with 4XLQFH\¶V-5, and is more reliable defensively.

Platform Year Statistics- Statistics during the 2011-12 season are quite similar. The key diference is TOI where Quincey averaged almost 4 more minutes of ice time, a huge gap.

2 www.capgeek.com

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Niskanen also only had 20 giveaways (GvA) WR 4XLQFH\¶V  Niskanen had 0.28 PTS/G

FRPSDUHGWR4XLQFH\¶V Again, these numbers would be more closely aligned had Niskanen played more minutes.

It is evident that given their age, career and platform statistics, Niskanen is the top comparable for Quincey. While he is earning $2,300,000, likely due to his inability to play more significant minutes, he is a good comparable in terms of his body of work to date.

K yle Quincey v. Marc Methot

K yle Quincey v Comparable Players Platform Season Statistics (Regular Season) Player Platform GP G A PTS PTS/ PIM PIM/G +/- TOI GvA G K yle Quincey 11-12 72 7 19 26 0.36 89 1.24 -1 21:52 35 Marc Methot 10-11 74 0 15 15 0.20 58 0.78 2 19:53 27

K yle Quincey v Comparable Players Career to Platform Season Statistics (Regular Season) Player GP G A PTS PTS/G PIM PIM/G +/- TOI K yle Quincey 257 18 77 95 0.37 250 0.97 -5 21:30 Marc Methot 229 6 38 44 0.19 208 0.91 5 18:48

0DUN0HWKRWLVD¶´SRXQGdefenceman, currently playing for the . He was a 6th round draft pick of the in the 2003 NHL Entry Draft. He signed a 4 year, $12,000,000 deal during the 2010-11 off-season.3

Games Played- Methot has played 28 fewer games than Quincey up to their respective platform years.

Durability- Methot has missed 30 games throughout his career to platform seasons. He has averaged approximately 67 games over the last three seasons leading up to his platform season.

He has also averaged 18:48 minutes per game throughout this time, which shows he is capable of playing significant minutes.

3 www.capgeek.com

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Career to Platform Statistics- Aside from PIM/G where Methot only averages 0.78 (Quincey-

1.24) and +/- (Methot: +2, Quincey: - DOORI4XLQFH\¶VFDUHHUWRSODWIorm statistics are superior to that of Methot. He has more G, A, PTS, PTS/G, and TOI.

Platform Year Statistics- The same can be said for their respective platform years. Aside from

PIM/G, giveaways, and +/-4XLQFH\¶VRIIHQVLYHRXWSXWDQG72,DUHVXSHULRU

While 0HWKRW¶VSODWIRUPVHDVRQwas WZR\HDUVSULRUWR4XLQFH\¶V they share the same age and have similar statistics throughout their career to platform years. As a result, Methot is an adequate comparable player.

K yle Quincey v. Josh Gorges

K yle Quincey v Comparable Players Platform Season Statistics (Regular Season) Player Platform GP G A PTS PTS/ PIM PIM/G +/- TOI GvA G K yle Quincey 11-12 72 7 19 26 0.36 89 1.24 -1 21:52 35 Josh Gorges 10-11 36 1 6 7 0.19 18 0.5 -3 21:10 24

K yle Quincey v Comparable Players Career to Platform Season Statistics (Regular Season) Player GP G A PTS PTS/G PIM PIM/G +/- TOI K yle Quincey 257 18 77 95 0.37 250 0.97 -5 21:30 Josh Gorges 364 9 50 59 0.16 183 0.50 12 19:40

-RVK*RUJHVLVD¶´SRXQGGHIHQFHPDQZLWKWKH0RQWUHDO&DQDGLHQV+HZHQWXQGUDIWHG and was signed as a free agent by the in 2002. He played his 1st NHL game during the 2005-06 season. He signed a 1-year, $2,500,000 RFA deal after the 2010-11 NHL season.4

Games Played- Gorges has played 107 more games than Quincey as he established himself as a regular early on in his career.

Durability- Gorges has missed 48 games due to injury during his career. He has also averaged

19:40 minutes on ice per game.

4 www.capgeek.com

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Career to Platform Statistics- Gorges is not known as an offensive defenceman. This can be seen in his PTS/G totals of 0.16. He is a responsible defensive player, with a +/- of +12 through his career to platform years.

Platform Year Statistics- Gorges was limited to only 36 games during his platform year as he dealt with a major knee injury.

Gorges is a good comparable player as he played his first NHL game in the same year as

Quincey (2005), is only a year older, and signed his RFA deal at the same age as Quincey (27).

He also signed a 1-year RFA deal which is line with what Quincey is seeking through arbitration.

K yle Quincey v. Marc Staal

K yle Quincey v Comparable Players Platform Season Statistics (Regular Season) Player Platform GP G A PTS PTS/ PIM PIM/G +/- TOI GvA G K yle Quincey 11-12 72 7 19 26 0.36 89 1.24 -1 21:52 35 Marc Staal 09-10 82 8 19 27 0.33 44 0.54 11 23:08 43

K yle Quincey v Comparable Players Career to Platform Season Statistics (Regular Season) Player GP G A PTS PTS/G PIM PIM/G +/- TOI K yle Quincey 257 18 77 95 0.37 250 0.97 -5 21:30 Marc Staal 244 13 39 52 0.21 150 0.61 6 21:53

Marc Staal was a 1st round pick (12th overall) by the in the 2005 NHL Entry

Draft. He is currently 25 years old, and signed a 5-year, $19,875,000 deal during the 2010 off- season (at the age of 23). While his age, platform season, and length of deal may not be ideal for comparative purposes, it is important to establish the market price for Quincey against a higher- paid RFA when there were, simply, no better players to choose from. It is important to zero in on two things. Firstly, the AAV on the deal is $3,975,000. Secondly, the salary in the first four- years of the deal, which would have accounted for his RFA eligible seasons (10-11: $3,100,000 salary; 11-12: $3,675,000 salary; 12-13: $3,775,000 salary; 13-14: $3,875,000 salary).5

5 www.capgeek.com

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Games Played- Staal has played 244 games leading up to his platform year, compared to

4XLQFH\¶V IHZHr games). This is a result of Quincey having played 5 more seasons than

Staal based on his age/current RFA status. Staal came into the league right out of junior (in 2007) and established himself immediately, playing 80 games. It took Quincey three years to establish himself as a full-time regular.

Durability- Both players have been durable throughout their careers. Leading up to his platform year, Staal only missed 2 games in three seasons, while Quincey has missed 88 games through his career. On the ice, they have both proven to be durable, averaging near identical TOI of 21:30

(Quincey) and 21:53 (Staal).

Career to Platform Statistics- Quincey has amassed 43 more points throughout his career

DYHUDJLQJ376*FRPSDUHGWR6WDDO¶V +RZHYHUStaal has only averaged 0.61 PIM/G while compiling a +/- of +6 (Quincey, -5).

Platform Year Statistics- Both players had very comparable platform season statistics. The only

GUDZEDFNLVWKDW4XLQFH\¶VSODWIRUPVHDVRQZDVLQZKLOH6WDDO¶VZDVLQ Furthermore,

Staal signed his contract at the age of 23, while Quincey is now 27. Staal played all 82 games in

2009-10, while averaging 0.33 points per game (Quincey averaged 0.36). Staal also accumulated only 44 PIM, an average of 0.54 per game (Quincey: 89 and 1.24, respectively). Staal was also

+11, with TOI of 23:08 (Quincey: -DQG 6WDDOKDGJLYHDZD\VWR4XLQFH\¶V DOEHLW with almost 2 more minutes of average ice time).

It was important for us to be able to make a comparison with a player whose AAV is higher than that requested by Quincey in order to establish his true market value. After doing a thorough

DQDO\VLVRIDOO5)$¶VRYHUWKHSDVWIHZVHDVRQV6WDDOVHHPVWREHWKHEHVWFRPSDUDEOHLQWKLV regard.

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I V. C O N C L USI O N

.\OH 4XLQFH\¶V previous RFA contract was a 2-year, $6,250,000 deal with an AAV of

$3,125,000 (his salary in 2011-12 was $3,250,000). While the player is going to request an increase in this new contract, the Club does not believe a significant raise is warranted. As stated above, there is no reason to believe that Quincey is a better player now than he was prior to signing the 2-year contract in 2010. He is a good defenceman with speed, size, and is capable of playing meaningful minutes. He also has a propensity to take too many penalties and is careless with the puck given his career +/- of -5 and 152 career giveaways. It was important to be able to pinpoint an appropriate AAV for Quincey by placing him within a comparable peer group. On the high-end, Marc Staal has an AAV of $3,975,000, but the first four-years of the deal (which were his RFA seasons) have an AAV of $3,606,250. It is to be noted that Staal is a 12th overall pick who is now entrenched as a legitimate top-2 shutdown defenceman in the NHL. On the other end of the spectrum, you have Matt Niskanen who signed a 2-year RFA deal with an AAV of $2,300,000. It has been noted that Niskanen is a solid comparable given his age, platform year, and comparable statistics. Given the increased salary cap since the 2010 season when

Quincey signed his first RFA deal, coupled with the fact that Quincey will be given every opportunity to play in the top-4 pairings, we believe he warrants a nominal raise. For all of these reasons, the Club respectively submits that Kyle Quincey should be paid $3,500,000 for the

2012-13 season.

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