IN THE MATTER OF A SALARY ARBITRATION BETWEEN:

MATS ZUCCARELLO

- AND -

THE

BRIEF IN SUPPORT OF THE PLAYER – MATS ZUCCARELLO

TEAM 26

Table of Contents

I. INTRODUCTION

A. Player Position …………………….……………….....……………………………. 2

B. Player Introduction ……………….………………………………………………… 3

1. Zuccarello’s Early Years .……………………………..…….………………. 4

2. Zuccarello’s Platform Year …………..………………..……………………. 5

C. Intangibles …………………………………….……………………………………. 5

II. COMPARABLE PLAYERS

A. Selection of Comparable Players …………………………………………………... 5

B. Comparable Player Essentials ….…………………………………………………... 6

C. Mats Zuccarello v. Comparable Players …….……………………………………... 7

i. Mats Zuccarello v Erik Condra ….………………………………………….. 7

ii. Mats Zuccarello v Trevor Lewis …….……………………………………... 7

iii. Mats Zuccarello v Nick Spaling ..…………………………………………. 8

iv. Mats Zuccarello v Nick Bonino ...………………………………………… 8

III. CONCLUSION …………………………………………………………………………... 9

1 I. INTRODUCTION

This brief analyzes the past performance and contributions of left wing Mats Zuccarello

(“Zuccarello” or the “Player”) and the New York Rangers Hockey Club (the “Rangers” or the

“Club”) of the (“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 ; 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. PLAYER POSITION

This brief will consider the essential criteria in turn. Mr. Zuccarello believes that he is a valuable depth contributor, and is seeking the opportunity to continue his time with the Club in order to earn a more valuable role with the Rangers. Based on the Player’s statistics from his platform year (“PY”) (the 2012-13 season) and his career performance, it is the position of the

Player and his agent that the appropriate average annual value (“AAV”) for Zuccarello’s contract for 2013-14 is greater than the $1.15 million midpoint figure. The Player respectfully requests that the panel find that he is entitled to a salary arbitration award of $1,150,001, as the Player

1 Article 12.1, National Hockey League and National Hockey League Players’ Association, Collective Bargaining Agreement – http://cdn.agilitycms.com/nhlpacom/PDF/NHL_NHLPA_2013_CBA.pdf

2 believes that this is an appropriate and fair value with respect to the NHL marketplace for depth forwards.

B. PLAYER INTRODUCTION

Mats Zuccarello is a 26 year old left wing who has accumulated 67 games in three seasons with the New York Rangers. The Rangers originally signed Zuccarello as a free agent in

2010. Zuccarello stands 5’7”, weighs 179 pounds, and was born in , Norway.2 Considered to have the career potential of a “creative playmaker,” Zuccarello is an asset due to his “creativity with the puck,” his considerable “offensive ability,” specifically as a playmaker.3 However,

Zuccarello is limited due to his size compared to the average NHLer, and deficiencies in his defensive abilities.4 The on-ice characteristics that Zuccarello brings to the Rangers are as follows: v Youth: As a relatively young forward, with respect to the typical retirement age of

established NHL forwards5, Zuccarello should be a reliable depth forward for the Rangers

for seasons to come. Zuccarello has limited NHL experience, but has proven himself as solid

offensive contributor, in both the NHL and KHL, and as a -per-game player in the AHL

with , and in Swedish Elite League with Modo.6 Zuccarello has also

demonstrated his ability to consistently contribute in the NHL playoffs. v Durability: Throughout his career there has been an absence of recurring injuries.

Zuccarello has not yet played a full 82 game season, as he has missed games due to injury

2 http://www.nhl.com/ice/player.htm?id=8475692 3 http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?7214 4 Ibid note 3 5 http://www.quanthockey.com/Distributions/RetireeAgeDistribution.php 6 Ibid note 2

3 on one occasion as he broke his wrist in 2012 (missed 8 regular season, and 20 playoff

games).7 v Consistency: Zuccarello’s performance has been relatively consistent with respect to points,

as he has averaged between .30 and .55 points per game (“P/GP”). Contributions with

respect to goals per game (“G/GP”) has trended up from .14 to .20, while assists per game

(“A/GP”) have been anywhere in the range of .10 to .40. Zuccarello has averaged over 14

minutes per game in two of his three seasons with the Club, and has yet to register a season

as a minus player.8

MATS ZUCCARELLO’S NHL CAREER STATISTICS (2009-2013) GP G A PTS +/- PIM PPT GWG S 2012-13 15 3 5 8 10 8 0 0 27 2011-12 10 2 1 3 0 6 1 1 10 2010-11 42 6 17 23 3 4 0 2 74

MATS ZUCCARELLO’S NHL PLAYOFF CAREER STATISTICS (2009-2013) GP G A PTS +/- PIM PPT GWG S 2012-13 12 1 6 7 -2 4 0 0 22 2010-11 1 0 0 0 0 2 0 0 1

MATS ZUCCARELLO’S NHL CAREER STATISTICS: OTHER (2009-2013) G/GP A/GP PTS/ H BKS GvA TkA EV PP SH AVG GP TOI TOI TOI TOI 2012-13 .20 .33 .53 27 15 5 6 14:00 2:24 :00 16:25 2011-12 .20 .10 .30 8 3 2 2 6:58 3:00 :03 10:02 2010-11 .14 .40 .55 56 19 6 16 11:37 2:32 :00 14:10

1. ZUCCARELLO’S EARLY YEARS

Following 2 years of development with Modo of the Swedish Elite League, Zuccarello transitioned quickly to North American hockey. Zuccarello has split his time between the

Rangers and their AHL affiliate, the Connecticut Whalers. In 73 games in the AHL, Zuccarello has scored 65 points (25 G, 40 A). Playing in 42 games as a rookie with the Rangers, Zuccarello

7 http://www.tsn.ca/nhl/teams/players/bio/?id=7214 8 http://www.nhl.com/ice/player.htm?id=8474125&view=splits

4 scored 6 goals and added 17 assists. In the following season Zuccarello’s production was limited as a result of injury and ice time, as he contributed 3 points (2 G, 1 A) in 10 games played in

2011-12. Zuccarello established himself as a reliable depth forward that could contribute on regularly given the opportunity to dress in the Rangers lineup.

2. ZUCCARELLO’S PLATFORM YEAR

In his PY, Zuccarello produced consistently with respect to his career averages, as he accumulated 8 points (3 G, 5 A) in 15 games in the lockout shortened season. Zuccarello also spent time in the KHL with Metallurg, tallying 28 points (11 G, 17 A) in 44 games. 9

While Zuccarello’s production has remained quite consistent, it is evident that he needs the opportunity to play regularly in the lineup to demonstrate his true potential. While he is limited to a role as a depth player at this point, Zuccarello believes that his salary should reflect his position on the depth chart, but believes that he should be compensated equally with respect to the non-traditional qualities that he brings to a depth role within the Rangers lineup.

C. INTANGIBLES

Zuccarello participates in the community programs hosted by the Rangers, including the

Annual Golf Classic.10 Furthermore, Zuccarello has demonstrated the potential to be an elite talent recognized as such by his fellow peers, as he was recognized as the most valuable player of the Swedish Elite League in his second season with Modo.11

II. COMPARABLE PLAYERS A. SELECTION OF COMPARABLE PLAYERS

When selecting comparable players, Zuccarello and his representative considered similarly productive forwards who were arbitration-eligible in the summer of 2012, or 2013.

9 Ibid footnote 2 10 http://blueshirtsunited.com/photos/3813/photo-gallery-31st-annual-rangers-golf-classic#.Ukuy7-PZ8Vk 11 http://en.wikipedia.org/wiki/Mats_Zuccarello-Aasen

5 The comparable players submitted are Erik Condra, Trevor Lewis, Nick Spaling, and

Nick Bonino. Given the above noted criteria, it is determined that the most comparable players are: Erik Condra and Trevor Lewis.

B. COMPARABLE PLAYER ESSENTIALS

CONTRACTUAL BACKGROUND12 Player Age Team Date Signed Contract Year New Contract AAV Mats Zuccarello 26 New Unknown 700,000 Unknown Unknown York Erik Condra 27 Ottawa July 2013 625,000 2,500,000 1,250,000 Trevor Lewis 26 LA July 2013 700,000 1,325,000 1,325,000 Nick Spaling 25 Nashville July 2013 1,100,000 1,500,000 1,500,000 Nick Bonino 24 Anaheim July 2012 693,000 1,400,000 700,000

CAREER TO PLATFORM YEAR STATISTICS Player GP G A PTS +/- PIM PPG GWG S Mats Zuccarello 67 11 23 34 13 18 1 3 111 Erik Condra 155 18 30 48 13 76 1 3 261 Trevor Lewis 203 12 25 37 -12 51 0 5 314 Nick Spaling 226 27 25 52 -24 56 2 7 265 Nick Bonino 85 6 14 20 -2 18 2 0 137

PLATFORM YEAR STATISTICS Player GP G A PTS +/- PIM PPG GWG S Mats Zuccarello 15 3 5 8 10 8 0 0 28 Erik Condra 48 4 8 12 3 34 0 0 73 Trevor Lewis 48 5 9 14 5 19 0 2 92 Nick Spaling 47 9 4 13 -10 18 1 2 57 Nick Bonino 50 5 13 18 1 8 0 0 63

PLATFORM YEAR STATISTICS: OTHER Player G/ A/ PTS/ H BKS GvA TkA EV PP SH AVG GP GP GP TOI TOI TOI TOI Mats Zuccarello .20 .33 .53 27 15 5 6 14:00 2:24 :00 16:25 Erik Condra .08 .17 .25 12 32 14 27 11:01 :02 2:06 13:10 Trevor Lewis .10 .19 .29 83 31 9 11 12:33 :48 1:50 15:12 Nick Spaling .19 .09 .28 38 21 7 22 13:31 :14 2:05 15:51 Nick Bonino .10 .26 .36 18 39 9 28 11:39 :44 :03 12:28

12 http://capgeek.com/

6 C. MATS ZUCCARELLO V. COMPARABLE PLAYERS i. MATS ZUCCARELLO V. ERIK CONDRA Erik Condra is a 27 year old right wing who has accumulated 155 games in three seasons with the . The Senators originally drafted Condra as the 211th pick in the 7th round of the 2006 NHL entry draft. Condra stands 6’0”, weighs 189 pounds, and was born in

Trenton, Michigan.

Zuccarello has had limited NHL experience compared to Condra; however, he has demonstrated the ability to contribute superior averages when he is in the lineup. In his PY,

Zuccarello averaged better than a half P/GP average, while Condra contributed a quarter P/GP.

Zuccarello demonstrated a superior plus/minus (“+/-“) average, and a willingness to play a much more physical game, with respect to hits, than Condra. While the two are utilized in different roles by their respective clubs, with respect to special teams ice time, it is safe to assume that if

Zuccarello were given the quantity of games, his output would be far superior to that of Condra.

While Condra is less of a playmaker and more of a grinder, the comparison is relevant with respect to salary based on contribution of points.

ii. MATS ZUCCARELLO V TREVOR LEWIS Trevor Lewis was a 26 year old center who had accumulated 203 games in 5 seasons with the by his arbitration-eligible summer. The Kings originally drafted Lewis as the 17th pick in the 1st round of the 2006 NHL entry draft. Lewis stands 6’1”, weighs 198 pounds, and was born in , .

Lewis is utilized by the Kings in a less offensive role than Zuccarello’s role; however,

Zuccarello’s average G/GP, A/GP, a P/GP are significantly superior even though the two are given similar amounts of ice time, and are similarly situated on their team’s respective depth charts. Zuccarello has posted almost identical career totals for goals, assists, and points, even though he has played 136 fewer games. Furthermore, Zuccarello has a far superior career

7 plus/minus at +13 to Lewis’ -10. Zuccarello demonstrates far greater offensive upside than

Lewis, which should counter for the assets which Lewis brings to the lineup.

iii. MATS ZUCCARELLO V NICK SPALLING Nick Spalling was a 25 year old left wing who had accumulated 226 games in 4 seasons with the . The Predators originally drafted Spaling as the 58th pick in the 2nd round of the 2007 NHL entry draft. Spaling stands 6’1”, weighs 201 pounds, and was born in

Palmerston, Ontario.

The utility of this comparable is limited as the two players are utilized in different roles, primarily with respect to special teams, by their respective teams, but contribute similar averages in terms of G/GP and time on ice. Furthermore, the playmaking ability of Zuccarello is accentuated in comparison to Spaling, as Zuccarello has accumulated almost as many career assists in 159 fewer games played. The averages suggest that given the same number of games played, Zuccarello would be on pace to accumulate the equivalent number of goals. Zuccarello is, with respect to his career statistics, a far more productive player. As a depth player, however,

Zuccarello does not have the physical attributes of the average NHLer apparent in Spaling.

iv. MATS ZUCCARELLO V NICK BONINO Nick Bonino was a 24 year old center who had accumulated 85 games in 3 seasons with the . The Sharks originally drafted Bonino as the 173rd pick in the 6th round of the 2007 NHL entry draft. Sekera stands 6’1”, weighs 196 pounds, and was born in Hartford,

Connecticut.

The comparable established between these two players is based on the use of each player by their respective teams, as the two are used in offensive situations for the most part, and with respect to the fact that the two players were not given the opportunity as a regular in the lineup.

Zuccarello is more productive than Bonino, as he has accumulated 14 more points (5 G, 9A) in

8 18 fewer games. Zuccarello also demonstrated a much more reliable game posting a +13 in contrast to Bonino’s -2. While the two players are depth players within their respective line-ups,

Bonino shows the traditional size but lacking of offensive production in contrast to Zuccarello.

III. CONCLUSION

Upon examining the player overview, career statistics, and comparison of comparable players herein, Zuccarello appears to have established himself as a depth forward in the NHL.

Zuccarello has limited experience compared to the other arbitration-eligible forwards; however, he has asserted superior offensive numbers throughout the course of his career. The relevant comparable forwards are depth players in their line-ups, and are not relied on to produce consistent offence for their salary. Zuccarello and his representation believes that the contracts for Condra and Lewis should be utilized to set the contract range between $1,250,000, and

$1,350,000 on the high end, as the two graduated from similar deals to Zuccarello to their current respective contracts, even though they were only as productive, with much greater opportunity within the lineup. Zuccarello has contributed more than Bonino, and should be compensated accordingly. The representatives concede Zuccarello’s limitations to the offense of the Rangers believing that he should be paid less than the other depth players until he is able to establish himself in a tradition top 6 forward role suited to his skill set.

With respect to the factors outlined herein, Mats Zuccarello believes that the proposed salary of $1,150,001 is fair and equitable compensation.

9