Team [3] Mats Zuccarello-Aasen and the Rangers Representing Mats Zuccarello-Aasen

I. INTRODUCTION AND REQUEST FOR HEARING DECISION

1This brief is filed on behalf of Mats Zuccarello-Aasen (hereinafter “Zuccarello) of the

New York Rangers in regards to his impending arbitration hearing. The

Player’s Association Collective Bargaining Agreement governs Zuccarello’s arbitration hearing.

(“CBA”). This brief will address Zuccarello’s value to the Rangers, specifically his reliability as a two-way defenseman, his ability to please the coaching staff as reflected in his high TOI totals, his inherent value to a highly competitive Rangers hockey club, and his high level of discipline.

Based on the findings hereinafter, this brief will provide evidence proving that Zuccarello should be awarded a salary above his midpoint of $1.15 million.

II. THE PERFORMANCE OF MATS ZUCARELLO

A. Mats Zuccarello’s 2012-2013 Platform Campaign

Mats Zuccarello played in 15 games in the shortened 2012-2013 campaign after terminating his contract in the KHL early to rejoin the Rangers in a push to make the playoffs2.

Despite having played in the KHL for nearly a full , needing to re-adjust to the smaller rink size in the NHL, and not having played with his Rangers teammates for over a year (his last game with the Rangers was March 23, 2012 and he returned on March 30, 2012), Zuccarello’s impact was immediate. He recorded 3 goals and 5 assists for 8 points in 15 games, which average to 0.533 points per game. He also boasted an impressive +10 plus/minus rating which was tied for fifth on the Rangers amongst all players. Zuccarello managed to record 27 shots on for a 1.8 per game average.

1 All stats are from www.nhl.com unless otherwise specified 2 http://www.newsday.com/sports/hockey/rangers/mats-zuccarello-rejoins-rangers-happy-to-be-back-with-his- former-team-1.4932808

With Zuccarello in the lineup, the Rangers went an astounding 10-4-1 for a 0.700 win percentage and solidified their berth in the playoffs with 56 points and a sixth place finish.

During the stretch in which Zuccarello played, the Rangers went into a shootout in two games.

In both of these games Zuccarello was selected to take a shot, and he ended up going 1/2. This is an important statistic because Zuccarello was the only player to convert in the shot out with the

Leafs on April 10, 2013. His goal held up to be the shootout winning goal and secured the

Rangers an all-important in the standings close to the arrival of the playoffs. The difference between sixth and ninth in the east was only five points, and the difference between sixth and eighth was only one, therefore every point was crucial to ensure the possession of a playoff position. Zuccarello also played in 12 post-season games for the Rangers, scoring 1 goal and tallying 6 assists for a 0.583 points per game average. He was the second highest scorer for the

Rangers in the post-season.

Zuccarello’s value also extends to the defensive side of the game. Zuccarello was able to maintain a 6 to 5 takeaway to giveaway ratio, as well as an impressive 15 blocked shots in 15 games for a 1 blocked shot per game average. He also threw 27 hits for a 1.8 hits per game average.

Furthermore, Zuccarello recorded 16: 25 (“TOI”) of ice time which ranked him amongst

New York’s top nine forwards in that department. A large part of his role during his TOI was spent on special teams, as he spent an average of 2:24 on the powerplay. He also recorded a shorthanded assist despite his rare deployment on the killing unit. Another notable factor about Zuccarello’s TOI was that it increased against the three most difficult opponents he faced in regards to winning percentage. Against these opponents he averaged 17:29 TOI in four games. Zuccarello’s value lies in his ability to contribute offensively while not being a defensive liability. These qualities are high priority for coaches and tend to be compensated accordingly.

Comparing Zuccarello to other players who possess similar statistics and playing characteristics will show that he deserves a contract above his midpoint of $1.15 million.

III. COMPARABLE PLAYERS

a. Trevor Lewis

Trevor Lewis is a 26-year-old forward for the . After the 2012-2013 lock- out shortened season Lewis was eligible for arbitration, but reached an agreement with the Kings and avoided arbitration. Going into arbitration Lewis was earning $725,000 per year3. During the lock-out shortened season, Lewis put up career numbers. The improvement in his game earned him a $600,000 raise, increasing his annual salary to $1,325,0004. A comparable contract should be awarded to Zuccarello as he has similar platform year numbers and career statistics. Lewis played more games in his platform year and has played more games in his career. In order to accurately reflect production levels for both players their statistics will be presented as per game averages.

Offensively Lewis had his strongest year in the lock-out shortened season, scoring 0.104 goals per game and 0.188 assists per game for a total 0.292 points per game. During the same season, Zuccarello out-performed Lewis scoring 0.200 goals per game and 0.333 assists for a total of 0.533 points per game. The numbers may be considered a bit skewed, as Zuccarello only played 15 games during the 2012-2013 season, while Lewis played 48 games. In order rectify this issue it may be beneficial to compare the 2010-2011 season, a year where both players participated in a minimum of 50% of the regular season games.

3 http://capgeek.com/player/1024 4 Id In 2010-2011 Zuccarello played his first season in the NHL, after being named the Most

Valuable Player in the Swedish Elite League.5 In his first year Zuccarello scored 0.142 goals per game and 0.405 assists per game for a total of 0.548 points per game. In the same 2010-2011 season Lewis played his first full NHL season, having played 5 and 6 games in his previous two seasons. Lewis contributed 0.042 goals per game and 0.139 assists per game for a total of 0.181 points per game. Offensively, in their respective first seasons, Zuccarello out-performed Lewis.

One attribute between the two players that was notably different was Lewis’ special teams minutes being played primarily on the penalty kill, while Zuccarello’s were not. However,

Zuccarello is a more offensive player who plays major minutes on the power play. Despite being the more offensively savvy player, Zuccarello’s defensive numbers are comparable to Lewis’. In the lock-out shortened season, Zuccarello blocked 1.000 shots per game and threw 1.8 hits per game. Lewis blocked less shots, 0.646 per game, and threw less hits 1.73. Again to draw a better comparison, looking to 2010-2011 season Zuccarello blocked 0.452 shots per game and threw

1.333 hits while Lewis blocked 0.347 and threw 1.42 hits.

As a less offensive player and a comparable defensive player, Lewis signed a $1,325,0006 contract with the Kings. Despite having fewer games played, Zuccarello has outperformed Lewis greatly in offensive categories, and slightly in defensive categories. Based upon Zuccarello’s superior performance in comparison to Lewis,’ he deserves a contract above his mid-point of

$1,150,000 per year.

5 http://newyork.cbslocal.com/2013/07/30/rangers-re-sign-forward-mats-zuccarello/ 6 Id b. Erik Kondra

Erik Kondra signed a two-year contract with the in the summer of 2013, avoiding arbitration. Kondra’s new contract will earn him an average of $1,250,0007 per year.

He is a 27-year-old who has played in the NHL for the last three years. Both Kondra and

Zuccarello started their NHL careers in 2010-2011. Kondra has played more games than

Zuccarello over that time, however his statistics are relatively lower then Zuccarello’s. In order to accurately compare the production levels of Kondra and Zuccarello it is beneficial to refer to stats on a per game basis.

Both players’ platform year was the 2012-2013 lock-out shortened season. Kondra played the full 48 games, while Zuccarello played 15 of those games. During the 2012-2013 season

Zuccarello’s offensive statistics were superior to Kondra’s. Kondra averaged 0.083 goals per game and 0.167 assists per game, for a total of 0.25 points per game, while Zuccarello averaged

0.200 goals per game and 0.333 assists for a total of 0.533 points per game. Offensively,

Zuccarello had the superior season, but even defensively Zuccarello outperformed Kondra.

Kondra is considered a defensive forward who plays on the third and fourth lines. Kondra also plays considerable shorthanded minutes, 2:06 minutes per game. Conversely, Zuccarello is considered an offensive player who has spent some time on the second line for the Rangers. He also plays substantial minutes on the power play, 2:24 per game. Notwithstanding the type of players they both are and the different special team minutes they play, Zuccarello has superior defensive numbers. Zuccarello averaged 1.8 hits per game and 1.00 blocked shots per game in the 2012-2013 season, while Kondra averaged 0.25 hits per game and 0.67 blocked shots per game in the same season. Even though Zuccarello played a third of Kondra’s games,

7 http://capgeek.com/player/1280 Zuccarello’s point per game percentages were two to three time higher, and his defensive numbers were considerably higher.

Looking to career totals, which provide a greater sample of games, Zuccarello’s superiority persists. Zuccarello over his career has averaged 0.164 goals per game and 0.343 assists per game for a total of 0.507 points per game, while Kondra has averaged 0.116 goals per game and 0.194 assists per game for a total of 0.0309 points per game. Defensively, Zuccarello averaged 1.36 hits per game and 0.55 blocked shots per game, while Kondra averaged 0.206 hits per game and a slightly better 0.787 blocked shots per game average.

As a less offensive gifted player and an equally gifted defensive player in comparison to

Zuccarello, Kondra was signed to a two-year $1.25 million8 contract. Kondra’s contract serves as an indicator of what a comparable, yet slightly inferior player should be earning. As a player with superior offensive numbers and equally impressive defensive numbers, Zuccarello’s contract should be equal to or exceed the $1.25 million9 level, which is above his salarymid- point.

c. Patrick Kaleta

Patrick Kaleta is 27-year-old winger for the . After the 2011-2012 season, at the age of 26, Kaleta signed a three-year contract with the Sabres worth $1.25 million10 per year prior to arbitration. This contract was worth 40%11 more then what Kaleta was previously earning per year. Kaleta began his career in 2008-2009 and has played considerably more games then Zuccarello. Further, Kaleta’s platform year was played in a full season, while Zuccarello

8 Id 9 Id 10 http://capgeek.com/player/393 11 Id played in a lock-out shortened season. In order to accurately assess the comparability of these players all statistics will be described as per game averages.

Offensively, Zuccarello has produced at a higher level. In his platform year Zuccarello averaged 0.200 goals per game and 0.333 assists for a total of 0.533 points per game. Over his career Zuccarello averaged 0.164 goals per game and 0.343 assists per game for a total of 0.507 points per game. Kaleta’s offensive numbers are much lower. In his platform year Kaleta averaged 0.079 goals per game and 0.079 assists per game for a total of 0.159 points per game, over three times less point production then Zuccarello. Over his career Kaleta has produced an average of 0.097 goals per game and 0.090 assists per game, for a total of 0.187 points per game.

Overall Zuccarello has produced points at three times the rate of Kaleta in his career.

Defensively, both players have put up similar numbers. In his platform year Kaleta threw

2.21 hits per game and blocked 0.730 shots per game, while Zuccarello threw 1.8 hits per game and blocked 1.00 shots per game. Even though Kaleta did throw more hits per game, he was also penalized at a higher rate, as Kaleta was penalized 1.50 minutes per game while Zuccarello was penalized only .32 minutes per game. This is significant because Kaleta would provide the opponent with more power play time, where there is a heightened probability of scoring. It is even more substantial for the Sabres, because Kaleta plays significant minutes on the penalty kill. The more time Kaleta is penalized and out of the game, the less time he spends assisting his team defensively, which is what he is primarily paid to do.

Kaleta is also susceptible to injuries and suspensions more often than Zuccarello. Injuries occur frequently, however when you are out for longer periods it has a greater impact on your team. This brief will only look at major injuries with a period longer then five games missed.

Kaleta had seven major injuries in his career and has missed 52 games, while Zuccarello has only had one major injury and missed 28 games. Further, Kaleta has been disciplined by the league on three occasions and has been suspended for 11 games over his career.

As a substantially more offensive, equally defensive and more penalized player than

Zuccarello, the Sabres gave Kaleta a raise of 40%12. Based on Zuccarelo’s performance when compared to Kaleta’s, it is clear that he has earned a similar if not greater contract then Kaleta.

IV. CONCLUSION

This brief thus submits that, in comparison to all of the aforementioned players, as well as with his value to the Mats Zucarello-Aasen deserves a raise in excess of his

$1.15 million salary midpoint. A failure to award him such salary would undermine his inherent value and would not adequately reflect the level of play he brings to the New York Rangers, as well as his comparative value to the valid comparable players submitted herein.

12 Id