IN THE MATTER OF A SALARY ARBITRATION

BETWEEN:

DERICK BRASSARD

(“THE PLAYER”)

-AND-

THE

(“THE CLUB”)

______

THE PLAYER’S BRIEF

______

TEAM 5

Counsel for “THE PLAYER”

Table of Contents

1. Introduction & Overview ...... 1 A. The Player’s Position ...... 1 B. ...... 1 2. Selection of Comparable Players ...... 2 3. Brassard vs. Gagner ...... 3 4. Brassard vs. Ennis ...... 5 5. Additional Considerations ...... 7 6. Conclusion...... 8

1

1. INTRODUCTION & OVERVIEW

[1] This is a matter of salary arbitration between Derick Brassard (“Brassard” or “the

Player”) and the New York Rangers (“the Rangers” or “the Club”), pursuant to Article 12 of the

2013 Collective Bargaining Agreement (the “CBA”) between the (the

“NHL”) and the National Hockey League Players Association (the “NHLPA”).

[2] Throughout this brief, all references to salary will be made using Average Annual Value.

A. THE PLAYER’S POSITION

[3] Based on Brassard’s offensive and defensive performance (both platform year and career), physical game, faceoff prowess, and additional considerations, appropriate compensation is at least $5,100,000 million.

B. DERICK BRASSARD

[4] Derick Brassard was a 1st round pick of the (6th overall) in the

2006 NHL Entry .1 On April 3rd 2013, Brassard was traded from the Columbus Blue Jackets

– along with , , and a 6th round draft pick – to the New York Rangers in exchange for Marian Gaborik and two minor league defensemen ( and Blake

Parlett)2. Brassard made his Rangers debut the night of the , scoring 1 and 3 assists3.

[5] Brassard is regarded as well-rounded, two-way forward with strong offensive upside.4 An excellent power play performer, the Player possesses a great wrist- and play-making ability5.

In the 2013-14 NHL Brassard posted 45 points (18 goals and 27 assists) and a +2 rating while playing in 81 games6.

1 http://www.nhl.com/ice/player.htm?id=8473544 2 http://www.sportsnet.ca/hockey/nhl/551969/ 3 http://scores.espn.go.com/nhl/recap?gameId=400443012 4http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5025 5 Ibid. 6 Supra note 1. 2

2. SELECTION OF COMPARABLE PLAYERS

[6] In order to properly assess the market value of Derick Brassard, comparable players must be selected to measure Brassard’s NHL performance against. Comparable players will be selected using the following criteria: age, platform year performance, career performance, style of play, role on their respective team, and NHL experience.

[7] The comparable players selected to use throughout the remainder of the brief are: Sam

Gagner, C, and Tyler Ennis, C, .

[8] Both these players are similar to Brassard in terms of age, statistical production, style of play (playmaking centers), role on their respective teams (scoring line forwards), and NHL experience. Both players also satisfy the requirements for arbitration eligibility as per the Official

HACC Rules and Article 12 of the CBA.

[9] Prior to signing a three year $4.8 million (AAV7) contract during the 2013 off-season,

Sam Gagner had 6 years of NHL experience with the Oilers. Gagner was selected 6th overall by the in the 2007 NHL Entry Draft8. Gagner is two years younger than

Brassard. Like Brassard, Gagner is regarded as an excellent playmaker with offensive upside9.

[10] Tyler Ennis, two years younger than Brassard, was selected 26th overall in the 2008 NHL

Entry Draft by the Buffalo Sabres10. Ennis was signed to a five year, $4.6 million contract during the 2014 off-season11. Like Brassard, Ennis is regarded is a talented playmaker seen as having significant potential12. Prior to signing his five year contract in the 2014 off-season, Ennis had 4 seasons of NHL experience.

7 http://capgeek.com/player/23 8 http://www.nhl.com/ice/player.htm?id=8474040 9 http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?6052 10 http://www.nhl.com/ice/player.htm?id=8474589 11 http://www.capgeek.com/player/1572 12 http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?6685 3

3. BRASSARD VS. GAGNER – BRASSARD DEMONSTRATES SIMILAR OFFENSIVE PRODUCTION WITH A MORE ‘COMPLETE’ GAME

[11] Brassard’s and Gagner’s career statistics are listed below.

Derick Brassard13 Sam Gagner14

Season Tm GP G A P PPG +/- Hits FO% Tm GP G A P PPG +/- Hits FO%

2007-08 Did not meet 25 GP threshold to constitute a rookie season (17 GP) Edm 79 13 26 49 0.62 -21 18 42%

2008-09 Cbj 31 10 15 25 0.81 +12 40 49% Edm 76 16 25 41 0.54 -1 28 42%

2009-10 Cbj 79 9 27 36 0.46 -17 97 42% Edm 68 15 26 41 0.60 -8 40 47%

2010-11 Cbj 74 17 30 47 0.64 -11 121 47% Edm 68 15 27 42 0.62 -17 24 44%

2011-12 Cbj 74 14 27 41 0.55 -20 137 45% Edm 75 18 29 47 0.63 +5 21 48%

Cbj/

2012-13 Nyr 47 12 17 29 0.62 +1 73 48% Edm 48 14 24 38 0.79 -6 35 44%

2013-14 Nyr 81 18 27 45 0.56 +2 124 48% Edm 67 10 27 37 0.55 -29 33 47%

[12] As the statistics above illustrate, the two players produce points at a comparable rate,

with both reliably registering between 0.54 to 0.64 points per game over an 82 game sample size.

[13] Although Gagner does hold a slight edge in historical offensive production, it is notable

that Brassard in his platform year out-performed Gagner not only in terms of PPG but also

absolute totals. This fact, combined with Brassard possessing a more complete game than

Gagner, justifies Brassard being compensated above Gagner’s salary of $4.8M – compensation

of at least $5.1M is warranted.

[14] Evidencing Brassard’s more complete game is his defensive superiority, as reflected by

his +/- rating. While Brassard has been a plus player since joining the Rangers (and for fully half

of his NHL career i.e. 3 out of 6 seasons), Gagner has been a plus player only once. Moreover, in

13 Supra note 1. 14 Supra note 8. 4

2013-14 Gagner was -29. Although Edmonton possessed a poor goal differential, Nail Yakupov was the only Oiler with a worse +/- rating (-33)15, negating any argument that Gagner’s +/- can be attributed to team shortcomings. Furthermore, Gagner turns the puck over far more frequently than Brassard. Since 2008-2009, Brassard has given the puck away 123 times in 386 games. By contrast, Gagner has committed 244 turnovers over the same period. This represents 121 additional giveaways, despite Gagner only playing in 16 more contests than Brassard (402 GP)

Giveaways Since 2008-09 80 60 40 Brassard 20 Gagner 0 2008-09 2009-10 2010-11 2011-12 2012-13 2013-14 Number of Giveaways of Number

[15] Moreover, Brassard contributes a physical element that Gagner lacks. Brassard has never registered less than 40 hits in a season. When playing close to 82 games, the Player has consistently posted 97 hits or more (often exceeding 120 hits). Gagner has never posted more than 40 hits in a season.

[16] Finally, Brassard is the better faceoff man. As their career FO%s indicate, Brassard has out-performed Gagner in this area 4 out of the 6 seasons they have simultaneously competed in the NHL. Although the difference in their FO% is slight, even slim margins make a significant difference over the duration of one’s contract. With centers taking 100s of draws per year – in some cases over 1000 – the implications for puck possession in key situations are substantial.

15http://www.nhl.com/ice/playerstats.htm?fetchKey=20142EDMSASALL&viewName=plusMinus&sort=p lusMinus&pg=2 5

4. BRASSARD VS. ENNIS – BRASSARD DEMONSTRATES SIMILAR OFFENSIVE PRODUCTION WITH A MORE ‘COMPLETE’ GAME

[17] The career statistics of Brassard and Ennis are listed below.

Derick Brassard16 Tyler Ennis17

Season Tm GP G A P PPG +/- Hits FO% Tm GP G A P PPG +/- Hits FO%

2007-08 Did not meet 25 GP threshold to constitute rookie season (17 GP) Did not play

2008-09 Cbj 31 10 15 25 0.81 +12 40 49% Did not play

Did not meet 25 GP threshold to constitute rookie season (10

2009-10 Cbj 79 9 27 36 0.46 -17 97 42% GP)

2010-11 Cbj 74 17 30 47 0.64 -11 121 47% Buf 82 20 29 49 0.60 0 42 22%

2011-12 Cbj 74 14 27 41 0.55 -20 137 45% Buf 48 15 19 34 0.71 +11 26 46%

Cbj/

2012-13 Nyr 47 12 17 29 0.62 +1 73 48% Buf 47 10 21 31 0.66 -14 28 42%

2013-14 Nyr 81 18 27 45 0.56 +2 124 48% Buf 80 21 22 43 0.54 -25 89 39%

[18] As illustrated above, Brassard’s offensive numbers are very comparable to those Tyler

Ennis. Excluding the 2011-12 season, during which Ennis missed significant time due to an

ankle injury18, the two players have never had their respective point totals separated by more

than 2 points. Therefore, based strictly on offensive production, Brassard warrants compensation

equal to Ennis (4.6M). However, given that Brassard possesses a much more “complete” game

than Ennis, it becomes clear that appropriate compensation must be over $4.6M – compensation

of at least $5.1M is warranted.

[19] Upon observing the number of hits each player delivers, it becomes readily apparent that

Brassard’s physical game trumps Ennis’. In 2013-14, Brassard posted 35 more hits than Ennis.

16 Supra note 1. 17 Supra note 10. 18 http://www.nhl.com/ice/news.htm?id=597280 6

Every season beforehand, Brassard at least doubled Ennis’ hit totals (including tripling them in

2011-12, and being 5 hits shy of doing so in 2010-11 as well).

# of Hits Since 2008-09 200 100 Brassard # of Hitsof # 0 Gagner 2008-09 2009-10 2010-11 2011-12 2012-13 2013-14

[20] Brassard is also a far superior face-off man. Ennis has recorded a FO% greater than 42% just once in his career (46% in 2011-12). Brassard, on the other hand, has posted a FO% of 47% or better 4 of his 6 NHL seasons. In the 2 seasons Brassard failed to reach the 47% mark, his

FO%s were 45% and 42%, respectively. The former is only 1% shy of Ennis’ career high (46%).

The importance of faceoff ability in a goes without saying given the importance of puck possession at critical game junctures.

Faceoff % Since 2008-09 60 40 Brassard

Faceoff % Faceoff 20 Gagner 0 2008-09 2009-10 2010-11 2011-12 2012-13 2013-14

[21] Finally, Brassard has displayed the ability to score when his team needs offence the most.

The Player’s game-winning-goal (GWG) figures dwarf those of Ennis and serve to justify the

Player being compensated at least $5.1M. Throughout his NHL career Ennis has registered only

2 GWG – an embarrassingly low total for a player of his offensive caliber. Brassard doubled

Ennis’ career GWG output in his platform year alone.

7

Derick Brassard19 Tyler Ennis20 Season Tm GP GWG Tm GP GWG 2007-08 Did not meet 25 GP threshold to Did not play constitute rookie season (17 GP) 2008-09 Cbj 31 1 Did not play

2009-10 Cbj 79 0 Did not meet 25 GP threshold to constitute rookie season (10 GP) 2010-11 Cbj 74 3 Buf 82 1 2011-12 Cbj 74 3 Buf 48 1 2012-13 Cbj/ Nyr 47 1 Buf 47 0 2013-14 Nyr 81 4 Buf 80 0

5. ADDITIONAL CONSIDERATIONS

[22] Brassard is a proven playoff performer, scoring above his regular season rate of production in the post-season. Given that Brassard’s comparable players either have no NHL playoff experience (Gagner) or a limited sample size dated by four seasons (Ennis), this further justifies Brassard being compensated at least 5.1M. The career playoff statistics of Brassard,

Gagner, and Ennis are listed below.

Career Playoff Statistics

GP G A P Points Per Game Post-seasons Participated In

21 Brassard 35 8 16 24 0.69 2014, 2013

Gagner22 N/A N/A N/A N/A N/A N/A

Ennis23 13 3 5 8 0.62 2011, 2010

19 Supra note 1. 20 Supra note 10. 21 Supra note 1. 22 Supra note 8. 23 Supra note 10. 8

6. CONCLUSION

[23] Brassard plays a similar style of game (playmaking forward) to both Gagner and Ennis and is assigned a similar role on his team (scoring line forward) while producing very comparable offensive numbers. However, Brassard possesses superior defensive abilities to both in addition to a far more advanced physical game. Brassard is also the best faceoff man of the three players – an extremely valuable skill in a centre. Unlike his comparables, the Player has a proven history of scoring in the , as well as a history of scoring far more GWGs than his comparable Tyler Ennis. Considering the above, fair compensation for the Player is at least

$5,100,000 – this figures represents an extremely modest increase over the salaries of comparable players ($4.8M) and Tyler Ennis ($4.6M). Such an increase is warranted to reflect the Player’s similar offensive production in light of his more “complete” game.