IN THE MATTER OF A SALARY ARBITRATION BETWEEN: CARL GUNNARSSON - AND - THE TORONTO MAPLE LEAFS BRIEF IN SUPPORT OF THE TORONTO MAPLE LEAFS HOCKEY CLUB TEAM 26 Table of Contents I. INTRODUCTION A. Club Position …………………….………………....………………………………. 2 B. Player Introduction ……………….………………………………………………… 3 1. Gunnarsson’s Early Years …………………………….…….………………. 4 2. Gunnarsson’s Platform Year …………..……………………………………. 5 C. Intangibles …………………………………….……………………………………. 5 II. COMPARABLE PLAYERS A. Selection of Comparable Players …………………………………………………... 6 B. Comparable Player Essentials ….…………………………………………………... 6 C. Carl Gunnarsson v. Comparable Players …………………………………………... 7 i. Carl Gunnarsson v Zach Bogosian ………………………………………….. 7 ii. Carl Gunnarsson v Anton Stralman ………………………………………... 7 iii. Carl Gunnarsson v Kyle Quincey …………………………………………. 8 iv. Carl Gunnarsson v Andrej Sekera ………………………………………… 8 III. CONCLUSION …………………………………………………………………………... 9 1 I. INTRODUCTION This brief analyzes the past performance and contributions of defenseman Carl Gunnarsson (“Gunnarsson” or the “Player”) and the Toronto Maple Leafs Hockey Club (the “Leafs” or the “Club”) of the National Hockey League (“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 season; 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. CLUB POSITION This brief will consider the essential criteria in turn. Mr. Carl Gunnarsson is a valued member of the Leafs organization, and it is in the interests of the club to keep the player with the team in future. With respect to Gunnarsson’s statistics from his platform year (“PY”) (the 2012- 13 season) and his career performance, it is the Leafs’ position that the appropriate average annual value (“AAV”) for Gunnarsson’s contract for 2013-14 is less than the $3.15 million midpoint figure. The Club respectfully requests that the panel find that he is entitled to a salary arbitration award of $3,149,999, as the Club believes that this is an appropriate and fair value for the Player with respect to the NHL marketplace for defensemen. B. PLAYER INTRODUCTION 1 Articticle 12.1, National Hockey League and National Hockey League Players’ Association, Collective Bargaining 2 Mr. Carl Gunnarsson is a 26 year old defenceman who has accumulated 224 games in four seasons with the Leafs. The Leafs originally drafted Gunnarsson as the 194th pick in the 7th round of the 2007 NHL entry draft. Gunnarsson stands 6’2”, weighs 196 pounds, and was born in Orebro, Sweden.2 Considered to have the career potential of a “stabilizing big minute defenseman,” Gunnarsson is an asset due to his “excellent frame and long reach,” ability to move the puck “quickly and efficiently out of danger,” and ability to serve in a shutdown or limited power play role.3 However, Gunnarson is limited as a “big minute defenseman” due to his inability to adopt a “physical game”, his alleged lack of strength, and overall lack of production.4 The on-ice characteristics that Gunnarsson brings to the Leafs are as follows: v Experience: As a relatively young defenseman, with respect to the typical retirement age of established NHL defenseman5, Gunnarsson should be a reliable defenseman in the league for seasons to come. Gunnarsson has already accumulated 224 games in his 4 year career, and has played significant minutes alongside Dion Phaneuf as Toronto’s top defensive pairing. The efficient and defensive style of Gunnarsson make him an ideal partner for offensive minded defensemen, and he has demonstrated the potential to continue to contribute to the Club’s defense. v Durability: Throughout the Player’s career there has been an absence of recurring injuries. However, Gunnarsson has yet to play a full 82 game season, as he has missed games due to: a hyper-extended elbow (missed 22 games in 2009-10); hand, ankle and shoulder injuries (missed 5 games in 2010-11); and a hip injury (missed 11 games in 2012-13).6 2 http://www.nhl.com/ice/player.htm?id=8474125 3 http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5218 4 Ibid note 3 5 http://www.quanthockey.com/DistriButions/RetireeAGeDistriBution.php 6 http://www.tsn.ca/nhl/teams/players/Bio/?id=5218 3 v Consistency: Gunnarsson’s performance has been relatively consistent with respect to points, as he has averaged between .25 and .41 points per game (“P/GP”). Contributions with respect to goals per game (“G/GP”) has trended down from .07 to .03, while assists per game (“A/GP”) have been anywhere in the range of .20 to .41. Gunnarsson has averaged over 21 minutes per game in three of his four seasons with the Club, and has split his career with two plus and two minus seasons.7 While his defensive efforts may be called into question due to his plus-minus (“+/-“) statistics, three of the four seasons saw the Club ice a team that was far from playoff contention. CARL GUNNARSSON’S NHL CAREER STATISTICS (2009-2013) GP G A PTS +/- PIM S 2012-13 37 1 14 15 5 14 28 2011-12 76 4 15 19 -9 20 89 2010-11 68 4 16 20 -2 14 69 2009-10 43 3 12 15 8 10 45 CARL GUNNARSSON’S NHL CAREER STATISTICS: OTHER (2009-2013) G/GP A/GP P/GP H BKS GvA TkA EV PP SH AVG TOI TOI TOI TOI 2012-13 .03 .38 .41 78 71 32 11 17:55 :45 2:35 21:16 2011-12 .05 .20 .25 114 152 65 34 17:50 1:12 2:38 21:42 2010-11 .06 .24 .29 63 120 44 24 14:17 1:20 2:36 18:14 2009-10 .07 .28 .35 46 77 36 8 16:48 1:51 2:46 21:26 1. GUNNARSSON’S EARLY YEARS Following 4 years of development with Linkoping of the Swedish Elite League, Gunnarsson quickly transitioned to the NHL, playing only briefly with Toronto’s AHL affiliate (12 games), before being called up by the Club where he has played since. Playing in 43 games as a rookie with the Club, Gunnarsson scored 3 goals and added 12 assists. In the following two seasons Gunnarsson’s production leveled off as he contributed 20 points (4 G, 16 A) in 68 games played in 2010-11, and 19 points (4 G, 15 A) in 76 games played in 2011-12. Gunnarsson 7 http://www.nhl.com/ice/player.htm?id=8474125&view=splits 4 established himself as a reliable defenseman that could contribute on occasion, but was primarily relied upon to play the harder minutes against the opposition’s top lines and on the penalty kill. 2. GUNNARSSON’S PLATFORM YEAR In his PY, Gunnarson produced consistently with respect to his career averages, as he accumulated 15 points (1 G, 14 A) in 37 games in the lock-out shortened season. Gunnarsson’s average G/GP (.03) declined, but his A/GP (.38) were at a career high. Gunnarsson finished +5 on the season, ranked second amongst the Club’s defensemen, and tied for 49th amongst all defensemen, and played an average of 21:16 per game, ranked 3rd on the Club, and 78th in the league.8 While Gunnarsson’s production has remained quite consistent, it is unclear if Gunnarsson’s offensive output is linked to the production of his current partner Phaneuf, nor is it clear whether his point production is trending up or down in future. It is clear, however, that Gunnarsson offers a reliable top defensive pairing when alongside Phaneuf,9 and consistent minutes on the Leafs penalty kill, which ranked 2nd in the NHL in 2012-13.10 C. INTANGIBLES Gunnarsson does not currently serve as a captain or alternate captain for the Club, but his duration of service with the team is noteworthy (currently one of five members remaining with the team since the 2009 season).11 Gunnarsson participates in the community programs hosted by the Leafs, including the Annual Visit to Sick Kids Hospital,12 A Night with Blue & White, and 8http://www.nhl.com/ice/playerstats.htm?season=20122013&GameType=2&team=&position=D&country=& status=&viewName=summary 9 http://www.defendinGBiGd.com/2013/5/6/4283942/dallas-stars-2013-nhl-phaneuf-gunnarsson- bouwmeester-michalek-giordano 10 http://espn.Go.com/nhl/statistics/team/_/stat/special-teams/sort/penaltyKillPct 11 http://www.tsn.ca/toronto/Blogs/jonas_sieGel/?id=432377 12 http://mapleleafs.nhl.com/cluB/paGe.htm?id=62155 5 the Leafs & Legends Charity Golf Classic.13 However, Gunnarsson has not adopted a substantial role in the community outside of what is required by the team. II. COMPARABLE PLAYERS A. SELECTION OF COMPARABLE PLAYERS In selecting comparable players, the Club considered similarly productive defensemen with comparable ice time who were arbitration-eligible in the summer of 2011, 2012, or 2013. The comparable players submitted at the outset are Zach Bogosian, Anton Stralman, Kyle Quincey, and Andrej Sekera. This brief will demonstrate that the most comparable players are: Stralman, Quincey, and Sekera. B. COMPARABLE PLAYER ESSENTIALS CONTRACTUAL BACKGROUND14 Player Age Team Date Signed Contract Year New Contract AAV Carl Gunnarsson 26 Toronto Unknown 1,325,000 Unknown Unknown Zach Bogosian 23 Winnipeg July 2013 2,500,000 5,142,857 5,142,857 Anton Stralman 26 New July 2012 900,000 1,700,000 1,700,000 York Kyle Quincey 27 Detroit July