IN THE MATTER OF A SALARY ARBITRATION BETWEEN:

CARL GUNNARSSON

- AND -

THE

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 ………………………………………….. 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 (“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 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 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 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 2012 3,125,000 3,775,000 3,775,000 Andrej Sekera 25 Buffalo July 2011 1,000,000 2,750,000 2,750,000

CAREER TO PLATFORM YEAR STATISTICS Player GP G A PTS +/- PIM S Carl Gunnarsson 224 12 57 69 2 58 231 Zach Bogosian 297 34 69 103 -42 237 635 Anton Stralman 265 13 79 92 -31 117 339 Kyle Quincey 257 18 77 95 -5 250 509 Andrej Sekera 233 12 55 67 5 80 259

PLATFORM YEAR STATISTICS Player GP G A PTS +/- PIM S Carl Gunnarsson 37 1 14 15 5 14 28 Zach Bogosian 33 5 9 14 -5 29 85 Anton Stralman 53 2 16 18 9 20 55 Kyle Quincey 72 7 19 26 -1 89 168

13 http://www.mlsefoundation.org/events 14 http://capgeek.com/

6 Andrej Sekera 76 3 26 29 11 34 88

PLATFORM YEAR STATISTICS: OTHER Player G/ A/ PTS/ H BKS GvA TkA EV PP SH AVG GP GP GP TOI TOI TOI TOI Carl Gunnarsson .03 .38 .41 78 71 32 11 17:55 :45 2:35 21:16 Zach Bogosian .15 .27 .42 79 50 28 12 19:23 1:44 1:59 23:07 Anton Stralman .04 .30 .34 76 71 12 11 15:16 1:12 :36 17:05 Kyle Quincey .07 .28 .35 46 77 36 8 16:48 1:51 2:46 21:26 Andrej Sekera .04 .34 .38 61 85 51 38 17:11 2:05 1:49 21:05

C. CARL GUNNARSSON V. COMPARABLE PLAYERS i. CARL GUNNARSSON V. ZACH BOGOSIAN Zach Bogosian is a 23 year old defenseman who has accumulated 297 games in five seasons with the and . The Thrashers originally drafted

Bogosian as the 3rd pick in the 1st round of the 2008 NHL entry draft. Bogosian stands 6’3”, weighs 215 pounds, and was born in Massena, New York.

While the P/GP of Bogosian was similar in his PY, Bogosian has consistently produced at a higher level throughout his career. With respect to the differences in age, development, and role on the team’s defense, the Leafs do not believe that these players are similar enough to consider this comparison legitimate. Furthermore, the Leafs believe this comparison is minimally persuasive at most, given the length of term granted to Bogosian in his arbitration hearing.

ii. CARL GUNNARSSON V ANTON STRALMAN Anton Stralman was a 26 year old defenseman who had accumulated 265 games in 5 seasons with the Leafs, , and by his arbitration- eligible summer. The Leafs originally drafted Stralman as the 216th pick in the 7th round of the

2005 NHL entry draft. Stralman stands 5’11”, weighs 190 pounds, and was born in Tibro,

Sweden.

Gunnarsson and Stralman scored similar P/GP averages in their PYs; however,

Gunnarson was utilized less on the power play (“PP”), but more on the penalty kill (“PK”) and in

7 the game overall. In an additional 41 games played in his career, Stralman had accumulated 23 more points (1 G, 22A) than Gunnarsson. With respect to considerations of time on ice (“TOI”) in the platform year, it is evident that Stralman was utilized more in an offensive role.

Considering the difference in their physical characteristics and utilization by their respective teams, the Club does not feel that the players are perfectly comparable.

iii. CARL GUNNARSSON V. KYLE QUINCEY Kyle Quincey was a 27 year old defenseman who had accumulated 257 games in 8 seasons with the , , and Avalanche. The Red

Wings originally drafted Quincey as the 132nd pick in the 4th round of the 2003 NHL entry draft.

Quincey stands 6’2”, weighs 207 pounds, and was born in Kitchener, .

These comparable players contributed similar P/GP their PYs; however, the two are distinguishable with respect to their roles on their respective team’s defense. Quincey was utilized more often in the role of an offensive defenseman, and expected to be a contributor to the Red Wings’ PP. Quincey was a year older at the time the contract was signed, and his career statistics reveal a player with more offensive potential, as he contributed 26 more points (6 G, 20

A) in 33 more games. The Club also noted that the production of the Player is trending down, contrasted with Quincey’s which was trending up in his PY.

iv. CARL GUNNARSSON V. ANDREJ SEKERA Andrej Sekera was a 26 year old defenseman who had accumulated 233 games in 5 seasons with the . The Sabres originally drafted Sekera as the 71st pick in the 3rd round of the 2004 NHL entry draft. Sekera stands 6’0”, weighs 201 pounds, and was born in

Bojnice, .

While Sekera is a less persuasive player due to his arbitration eligibility occurring outside the period of relevancy, the Club believes that this is a relevant comparison. Gunnarsson and

8 Sekera produced very similar averages in their PY, with the greatest distinguishing factor being the difference in PP time allotted to the two defensemen. The two were similarly responsible for approximately 21 minutes per night, and performed the similar role of consistent, and efficient shut down defenseman.

III. CONCLUSION

Although the Player has limited experience compared to the other arbitration-eligible defensemen, he has asserted similar offensive numbers throughout the course of his career. The relevant comparable defensemen are offensive defensemen, utilized by their clubs in offensive situations. The club believes that the contracts for Stralman and Quincey should be utilized to set the contract window $1,700,000 and $3,750,000. With respect to the less persuasive contract of

Sekera, the market for more defensively inclined defensemen is established around $2,750,000.

While Gunnarsson established similar production to that of Quincey in his platform year,

Quincey has a history of being more offensive productive throughout his career, and seems to be an aberration with respect to value. The other similarly productive defensemen were all paid less than $3,000,000. The club concedes Gunnarsson value to the defense of the Maple Leafs believing that he should be paid more than the other similarly productive defensemen, but not substantially more.

With respect to the factors outlined herein, the Toronto Maple Leafs Hockey Club believes that the proposed salary of $3,149,999 is fair and equitable compensation.

9