IN THE MATTER OF SALARY ARBITRATION

BETWEEN:

MATS ZUCCARELLO

(“THE PLAYER”)

AND

THE

(“THE CLUB”)

THE CLUB’S BRIEF

TEAM 11

Counsel for “THE CLUB”

Table Of Contents

I. Introduction: pg.1

II. Player Assessment: Mats Zuccarello: pg. 1

a) Player Overview: pg.1

b) Pre-NHL Career: pg.2

c) NHL Career pg.2

i) Overall Performance in Previous Seasons and Statistics in the NHL:

pg.2

ii) Games Played/ Injury History: pg.3

iii) The length of Service of the player in the NHL or with the Club: pg.3

iv) The overall contribution to his club in the preceding : pg.4

III. Player Comparison: Zuccarello vs Nick Bonino and Mathieu Perreault: pg.4

a) Criteria for Selecting Comparable Players: pg.4

b) Zuccarello vs Bonino: Not as different as you might think: pg.5

c) Zuccarello vs Perreault: Why Perreault is Equal to or better than

Zuccarello: pg.6

IV. Conclusion: pg.8

1

I. Introduction

This brief has been prepared on behalf The New York Rangers (The Club) in regard to its salary arbitration proceedings with forward Mats Zuccarello (The Player). This brief will begin with a player overview of Mats Zuccarello, then consider his pre-NHL career before launching into a more comprehensive analysis of Mr. Zuccarello’s value as an

NHL player by considering the following factors pursuant to Article 12 of the current

CBA: 1) the overall performance of the player in previous NHL seasons, 2) number of games played/injury history, 3) length of service in the NHL or with the Player’s club and

4) the overall contribution of the player to the success or failure of his Club in the preceding season. This brief will then compare Zuccarello’s performance in the NHL to

Nick Bonino and Mathieu Perreault. The brief takes the position that as of each player’s year of eligibility, Zuccarello was not dissimilar to Bonino and less valuable than, or, in the alternative, equal in value to Perreault. The brief then concludes that any award of salary granted to Mr. Zuccarello should be less than the midpoint figure of $1,150,000.

II. Player Assessment: Mats Zuccarello a) Player Overview

Mats Zuccarello, from , Norway signed with the New York Rangers as an undrafted free agent on May 26 2010.1 Zuccarello is 5’7” and weighs 179 pounds.2 As of this off- season Zuccarello has played in parts of three seasons with the New York Rangers. In the

2012-2013 season, his platform year, Zuccarello played only 15 of the 48 games in the shortened season scoring 3 goals and adding 8 assists while finishing with a +/- of 10.3

1 http://rangers.nhl.com/club/player.htm?id=8475692 2 Ibid. 3 Ibid. 2 b) Pre-NHL Career

Zuccarello played junior hockey in Norway for several years before making the jump to playing pro hockey in Sweden in 2008. In 2008-09 and 2009-10, Zuccarello played two seasons of club hockey with Ornskolsvik in the Swedish Elite League before signing with the New York Rangers during the 2010 off-season.4 Zuccarello’s

NHL career has accordingly been shorter than many other players of his age. c) NHL Career

i) Overall Performance in Previous Seasons and Statistics in the NHL

Season ▴ Age Tm Lg GP G A PTS GC +/- PIM EV PP SH GW EV SH PP S S% TOI ATOI

2010-11 23 NYR NHL 42 6 17 23 8 3 4 6 0 0 2 8 0 9 74 8.1 595 14:10

2011-12 24 NYR NHL 10 2 1 3 1 0 6 1 1 0 1 0 0 1 10 20.0 100 10:03

2012-13 25 NYR NHL 15 3 5 8 3 10 8 3 0 0 0 3 1 1 27 11.1 246 16:25 Career NHL 67 11 23 34 12 13 18 10 1 0 3 11 1 11 111 9.9 942 14:04

5 Zuccarello has played only 67 games in the NHL as of this off-season scoring 11 goals and adding 23 assists. Zuccarello is a +13 over his NHL career and has averaged 0.51 points per game. In his platform year Zuccarello averaged 16:25 minutes of ice time and

0.53 points per game. Yet it is important to remember that Zuccarello only played 15 regular season games in his platform year, an incredibly small sample size from which to draw conclusions about his value. Moreover, if we take a closer look at Zuccarello’s numbers over his 15 games last season, some perspective can be had. Most notably in the last 6 games of the season Zuccarello posted 5 of his 8 points and had a +/- of +8.6 The

Rangers played 4 teams over those six games: the twice, the New Jersey

Devils twice, the and the Buffalo Sabres.7 None of these teams were

4 Ibid. 5 http://www.hockey-reference.com/players/z/zuccama01.html 6 http://www.hockey-reference.com/players/z/zuccama01/gamelog/2013/ 7 Ibid. 3 in a playoff race towards the end of the season and all these teams finished towards the bottom of the standings in the Eastern Conference; Florida finishing in last place.8 Thus,

Zuccarello’s impressive statistics from last year derive from strong showings against weak teams who were out of the playoff hunt towards the end of a shortened NHL season. Moreover, in the year before his platform year, Zuccarello only played ten games.

Besides the 2010-11 season, there is not a very strong body of work from which to draw conclusions about Zuccarello’s value as an NHL player. The fact is that he has yet to prove that he can sustain the kind of statistical success he posted in 2010-11.

ii) Games Played/Injury History

Over the 2010-11, 2011-12 and 2012-13 seasons Zucarello has played in 42, 10 and 15 games respectively, totaling 67 games for his career.9 As such the greatest source of information regarding Zuccarello’s value as an NHL player comes from his 2010-11 season, two years removed from his off-season of eligibility. Zuccarello has no history of any chronic injuries as an NHL player. In March 2012 he suffered a broken wrist missing the last 8 games of the regular season, and the following 20 games that year in the playoffs.10

iii) The length of Service of the Player in the NHL or with the Club

Zuccarello has spent his entire NHL career with the New York Rangers, yet has only played 67 games for them over parts of three seasons. Zuccarello’s length of service in the NHL is less than many players who began their pro hockey career in the NHL as opposed to abroad. Thus, if anything, a consideration of length of service in the NHL may be argued to Zuccarello’s detriment. The Club however takes the position that

8 http://www.nhl.com/ice/standings.htm?season=20122013&type=DIV 9 Supra note 5. 10 http://www.tsn.ca/nhl/teams/players/bio/?id=7214 4 neither the length of service with the Rangers nor the length of service in the NHL has any material impact to the case at hand.

iv) The overall contribution to his club in the preceding season

The most salient in determining Zuccarello’s value to his team in the preceding season is the simple fact that he only played 15 of his team’s 48 regular season games in his platform year. A player who plays in less than a third of his team’s games can hardly have had a major impact on his club’s overall success. Moreover, Zuccarello’s average ice-time of 16:25 minutes per game is most consistent with a role as a third line forward.11 Zuccarello was therefore not a central player on the Rangers’ line-up. Finally, as mentioned earlier in this brief, most of Zuccarello’s statistical success came in the final six games of the season against teams out of the playoff race. Zuccarello was not a consistent contributor but rather a player who in the last six games of the regular season had a “flash in the pan” impact. In sum then, the Club takes the position that Zuccarello’s contributions to the club, although positive, were nominal.

III. Player Comparison: Zuccarello vs Nick Bonino and Mathieu Perreault a) Criteria for Selecting Comparables

The following criteria were considered in finding comparable players to Mats Zuccarello: points per game, games played in the NHL, seasons played in the NHL (at least 10 games), average time on ice, and age (as of September 15 of the player’s year of eligibility). A comprehensive search yielded two relatively similar players to Mats

Zuccarello: Nick Bonino and Mathieu Perreault.

11 Supra note 5. 5

Player PPG Gms Played Seasons ATOI Age Zuccarello 0.51 67 3 14:04 26 Perreault 0.44 120 3 11:52 24 Bonino 0.24 85 2 11:51 24 12 b) Zuccarello vs Bonino: Not as different as you might think

Nick Bonino is a forward with the . He was drafted in the 2007 NHL

Entry Draft in the 6th round and 173rd overall.13 He weighs 196 lbs. and is 6’1”.14 During the 2012 off-season Bonino was eligible for salary arbitration but settled with the Ducks for a two-year contract worth $700,000 per year.15 Below are Bonino’s stats as an NHL player:

Season Age Tm Lg GP G A PTS GC +/- PIM EV PP SH GW EV SH PP S S% TOI ATOI

2009-10 21 ANA NHL 9 1 1 2 1 0 6 0 1 0 0 1 0 0 14 7.1 128 14:13

2010-11 22 ANA NHL 26 0 0 0 0 -3 4 0 0 0 0 0 0 0 23 0.0 255 9:48

2011-12 23 ANA NHL 50 5 13 18 6 1 8 5 0 0 0 12 0 1 63 7.9 624 12:29 16 At first glance, Zuccarello might look to be much better than Bonino as of his year of eligibility. However, the Club takes the position that although Zuccarello is worth more than Bonino as of his year of eligibility, if Bonino is worth 700, 000 a year, then

Zuccarello should be worth less than $1,150, 000 a year.

There is a glaring difference in terms of point per game averages between the two players. Zuccarello was averaging 0.51 points per game as of his year of eligibility while

Bonino was averaging only 0.24.17 However, Bonino contributed zero points during the

2010-11 campaign in which he played less than ten minutes a game. His lack of offensive output that year can be chalked up to playing in a fourth-line checking role with limited

12 http://www.hockey-reference.com/players/z/zuccama01.html; http://www.hockey- reference.com/players/b/boninni01.html; http://www.hockey-reference.com/players/p/perrema01.html 13 http://ducks.nhl.com/club/player.htm?id=8474009 14 Ibid. 15 http://www.capgeek.com/player/1642 16 http://www.hockey-reference.com/players/b/boninni01.html 17 Ibid. 6 minutes. In his platform year, however, Bonino saw 12:29 minutes per game and produced 18 points in 50 games for an average of 0.36 points per game. As such

Bonino’s offensive production is not as far off from Zuccarello’s if we discount Bonino’s

2010-11 campaign as an outlier. Moreover, Zuccarello has seen a few more minutes per game than Bonino has during his NHL career. If Bonino were to see the same number of minutes as Zuccarello, his point production would likely reach the 0.4 range, even closer to Zuccarello’s average. Bonino had also played more games (85) than had Zuccarello

(67) as of their respective years of eligibility. Finally, Bonino’s platform year saw him play 50 games, and saw him improving in leaps and bounds from the previous seasons.

Zuccarello’s platform year, as previously discussed is a very small sample size from which to draw conclusions about his value. In fact in the two seasons before his eligibility, Zuccarello only played a combined 25 games. In sum then the Club takes the position that while Bonino was less valuable than Zuccarello as of their respective years of eligibility, the disparity between Bonino’s salary of 700,000 per year compared to the proposed salary of 1,150,000 for Zuccarello is far too great given that the two players are not so dissimilar in value as of their years of eligibility. Accordingly, the Club takes the position that a comparison between Zuccarello and Bonino weighs in favour of the conclusion that Zuccarello should be awarded less than $1,150,000 per year. c) Zuccarello vs Perreault: Why Perreault is Equal to or better than Zuccarello

Mathieu Perrault was drafted in the 6th round of the 2006 NHL Entry draft and 177th overall.18 Perreault is 5’10” and weighs 185 lbs.19 In the 2012 off-season Perreault was eligible for salary arbitration but was able to come to an agreement with the Washington

18 http://capitals.nhl.com/club/player.htm?id=8473618 19 Ibid. 7

Capitals for a two year contract worth $1,050,000 per year.20 Below are Perreault’s NHL stats as of his year of eligibility:

Season Age Tm Lg GP G A PTS GC +/- PIM EV PP SH GW EV SH PP S S% TOI ATOI

2009-10 22 WSH NHL 21 4 5 9 4 4 6 3 1 0 0 5 0 0 27 14.8 238 11:21

2010-11 23 WSH NHL 35 7 7 14 6 -3 20 6 1 0 1 5 0 2 41 17.1 416 11:53

2011-12 24 WSH NHL 64 16 14 30 13 9 24 14 2 0 4 14 0 0 60 26.7 770 12:02 21 Aside from Zuccarello’s slightly stronger points per game average (0.51 compared to

0.44),22 the Club takes the view that in many other respects, Perreault’s NHL record shows him to be a more valuable player than Zuccarello. First of all, as of his year of eligibility Perreault was a more proven NHL player than Zuccarello. Perrault had played

120 games as opposed to Zuccarello’s 67. Moreover, Perreault’s platform year was his strongest showing. In that season, Perreault played 64 games and scored 16 goals (5 more than Zuccarello has scored in his entire career) and added 14 assists for a point per game average of 0.47.23 By contrast, as has been discussed, Zuccarello played only 15 games in his platform year. Coming into his year of eligibility then, Perreault was on an upward trajectory in terms of his performance as an NHL player whereas Zuccarello came into his year of eligibility with a combined 25 NHL games played in the previous two seasons and by extension much more uncertainty as to his value. Perreault’s +/- rating of +9 in his platform season is also very impressive given that Washington was a combined -8 as a team. By contrast, we know that Zuccarello’s +10 was largely derived from going a +8 in his last 6 games against weak teams out of the playoff hunt. More stock can be placed in a player going +9 over the course of 64 games than a player going +8 in the last six games of the season against weak teams to finish at +10 over 15 games. Moreover, in

20 http://www.capgeek.com/player/1203 21 http://www.hockey-reference.com/players/p/perrema01.html 22 Ibid. 23 Ibid. 8

Zuccarello’s first NHL season, he went +3 and in his second season he was a 0. The +10 should therefore be seen as an outlier.

In sum the Club takes the view that, on the whole, Perreault was more valuable than, or, at the very least, equal to Zuccarello as an NHL player as of their respective years of eligibility for salary arbitration. Accordingly, the Club takes the position that any award of salary to Mr. Zuccarello should be equal to or less than the $1,050,000 per year value of Perreault’s contract, or, in the alternative, less than the proposed value of $1,150,000 per year.

IV. Conclusion

The club respectfully submits that based on comparing Mats Zuccarello to both Nick

Bonino and Mathieu Perreault that an award of salary to Mr. Zuccarello of $1,150,000 is too high. The Club therefore respectfully requests that any award of salary to Mr.

Zuccarello should be less than $1,150,000.