IN THE MATTER OF AN ARTICLE 12 SALARY ARBITRATION PURSUANT TO THE ’S COLLECTIVE BARGAINING AGREMEENT

BETWEEN:

MATS ZUCCARELLO

-AND-

THE

BRIEF IN SUPPORT OF MATS ZUCCARELLO

TEAM 5

Table of Contents

1. INTRODUCTION & OVERVIEW...... 2 A. PLAYER’S POSITION...... 2 B. AN INTRODUCTION TO MATS ZUCCARELLO ...... 2 2. SELECTION OF COMPARABLE PLAYERS ...... 3 3. PLATFORM YEAR PERFORMANCE ...... 4 4. CAREER PERFORMANCE ...... 5 5. ADDITIONAL CONSIDERATIONS ...... 6 6. CONCLUSION ...... 9

Page | 1

1. INTRODUCTION & OVERVIEW

[1] This is a matter of salary arbitration between Mats Zuccarello (“Zuccarello” 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 National Hockey League

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

[2] The Player had the opportunity to seek offers from other NHL franchises notwithstanding receiving a Qualifying Offer from the Blues on July 1st, 2013 1. The Player subsequently elected to file for salary arbitration with the Rangers organization 2, pursuant to his right under Article

12.2 of the CBA .

A. PLAYER’S POSITION

[3] Considering the Player’s demonstrated ability to tally points at the NHL level, along with his extensive, successful history of professional hockey in the Russian Kontinental Hockey

League (KHL) and Swedish Elite League (SEL), a one-year contract worth $1,150,000 is below fair market compensation. Based on comprehensively analyzing the Player’s NHL production, non-NHL professional production and special qualities/considerations, the Player respectfully requests compensation in the range of $1.2 to $1.35 million.

B. AN INTRODUCTION TO MATS ZUCCARELLO

[4] Mats Zuccarello took a non-traditional path to the NHL. Unlike many talented and offensively gifted prospects, Mats was never drafted by an NHL team. The New York Rangers, however, saw promise in the talented forward and signed him to a two-year entry level contract

1 See http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5722 . 2 See http://www.tsn.ca/nhl/story/?id=427445 . Page | 2 in May of 2010 3. Zuccarello is one of the most gifted players ever to come out of Norway 4.His main assets are his creativity with the puck, playmaking ability, and general offensive talent 5. He also has significant speed and vision on the ice 6, and is a power play and shootout specialist 7.

2. SELECTION OF COMPARABLE PLAYERS [5] In order to properly assess the value of Mats Zucarello in the NHL marketplace, it is understandably necessary to evaluate his performance in the league with comparable players.

The most relevant criteria to determine a proper comparison are age, NHL experience, career and platform year statistics, and also each player’s role on their respective teams.

[6] Two comparable players will be used throughout the remainder of the brief. These players are: Nick Spaling, LW, and Cam Atkinson, RW, Columbus Blue

Jackets. These players are close comparables to Mats Zuccarello and all had entered the 2012-13 off as Restricted Free required by Article 12.1(a)-(b) of the CBA to be arbitration eligible.

Table 1 below presents the similarities in the relevant criteria of age and NHL experience.

Table 1: Mats Zucarello v Comparable Player Contracts Non-NHL AAV NHL Current Age at Platform Professional (Average Player Experience Age Signing Year Experience 8 Annual (years/games) (years/games) Value) 9 Zucarello 26 26 2012-2013 3/67 5/216 N/A Spalling 25 24 2012-2013 4/226 3/142 $1,500,000 Atkinson 24 24 2012-2013 2/62 2/89 $1,150,000

3 Supra note 1and see also http://rangers.nhl.com/club/news.htm?id=679173 . 4 See The Hockey News profile: http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?7214 . 5 Ibid. 6 See HockeysFutrure , “Talent analysis”: http://www.hockeysfuture.com/prospects/mats_zuccarello-aasen-2/ . 7 http://www.nytimes.com/2013/07/31/sports/hockey/zuccarello-re-signs-with-rangers.html . 8 Includes experience in the (AHL) for all three players, as well as experience in the KHL and SEL for Zuccarello (includes playoffs). Statistics sourced from: http://rangers.nhl.com/club/player.htm?id=8475692 (Zuccarello); http://predators.nhl.com/club/player.htm?id=8474096 (Spaling); and http://bluejackets.nhl.com/club/player.htm?id=8474715 (Atkinson). 9 Salary statistics sourced from: http://capgeek.com/player/1777 (Zuccarello); http://capgeek.com/player/1954 (Atkinson); and http://www.capgeek.com/player/1073# (Spaling). Page | 3

[7] The comparable players group all have 2-4 years of experience in the NHL and are less than two years apart in age. While Zuccarello has far more non-NHL professional experience than Cam Atkinson, Atksinon has played a similar amount of games in the NHL. Zuccarello and

Atkinson are both similarly offensively talented players 10 . Both are of a similar build of 5’7” and between 170-180 pounds. Both players add offensive depth to their team.

[8] Spaling is somewhat of a different type of player than Zuccarello. Spaling is not as offensively talented and doesn’t produce offensive numbers near Atkinson or Zuccarello.

However, Spaling and Zuccarello are both touted to be defensively responsible and able to play a two-way game and bring special teams ability 11 . Spaling is larger than the two players, allowing him to play a bit more of a physical game. However, prospects have observed Zuccarello is not afraid to take the body or be involved physically 12 .

3. PLATFORM YEAR PERFORMANCE

[9] The Platform Year performance compares the performance of a players the year prior to the salary arbitration. Looking first at production, it may seem both Atkinson and Spaling had better offensive years producing 10 and 5 more points, respectively. However, both players played significantly more games than Zuccarello. However, that isn’t the whole picture.

Table 1: Mats Zucarello v Comparable Players Platform Year Statistics 13 Player Year GP G A PTS +/- Zucarello 12-13 15 3 5 8 10 Spalling 12-13 47 9 4 13 -10 Atkinson 12-13 35 9 9 18 9

10 See The Hockey News player profile: http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?6602 ; and see 11 See http://www.eliteprospects.com/player.php?player=12462 , http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?6222 and http://www.eliteprospects.com/player.php?player=10881 . 12 See http://www.eliteprospects.com/player.php?player=10881 . 13 Supra note 8, NHL statistical sources. Page | 4

Platform Year PPG Nick Spaling 0.277

Mats Zuccarello 0.533

Cam Atkinson 0.514

0.000 0.100 0.200 0.300 0.400 0.500 0.600

Figure 1: comparable players platform year points-per-game production

[10] Zuccarello only joined the Rangers for the end of the 2012-13 season after signing a contract on March 26, 2013 14 . Zuccarello played out the playoffs in the Russian Kontinental

Hockey League before returning to the NHL for the end of the season. Figure 1 above shows

Zuccarello had a far better points-per-game (PPG) year than Spaling. Atkinson also produced

less points per game than Zuccarello. In addition, Zuccarello was +10 compared to Spaling’s -10,

demonstrating Zuccarello is not a liability when on the ice. As a player arguably paid more to be

physical and a solid two-way player, Spaling is not getting the job done in the defensive zone.

[11] After returning for the end of the season, Zuccarello also made a significant contribution

to the Rangers post-season run. Zuccarello skated in 12 playoff games, a sign of confidence that

the rangers kept him in the lineup after a strong end to the season. During the playoffs,

Zuccarello ranked second on the team in assists (6) and playoff points (7), making a significant

contribution to the Rangers making it to the second round of the playoffs. By comparison,

Spaling had only 3 points in 10 playoff games. Atkinson has yet to skate in a NHL playoff game.

4. CAREER PERFORMANCE

[12] Mats Zuccarello has scored slightly fewer goals than Cam Atkinson over the course of his career in the NHL. However, Zuccarello has demonstrated his ability to be a playmaker in

14 Supra note 4. Page | 5 addition to scoring, as he has seven more assists than Atkinson (see table 2 below). Both players have near identical PPG production, each being just over 0.50 (see figure 2 below). Zuccarello and Atkinson have much better +/- ratings, reiterating the comments from the Platform Year.

This demonstrates Zuccarello can consistently produce points and keep avoid having opposing teams score while on the ice.

Table 2: Mats Zucarello v Comparable Players Career to Platform Season Statistics 15

Player GP G A PTS PIM +/- Zucarello 67 11 23 34 18 13 Spalling 226 27 725 52 56 -24 Atkinson 62 16 16 32 18 9

Career PPG Cam Atkinson 0.516

Nick Spaling 0.230

Mats Zuccarello 0.507

0.000 0.100 0.200 0.300 0.400 0.500 0.600

Figure 2: comparable players’ career points-per-game production

5. ADDITIONAL CONSIDERATIONS

[13] Since coming to North America, Zuccarello has had success in both the NHL and the

AHL. In addition to playing games for the Rangers in the 2010-11, 2011-12 and 2012-13 seasons, Zuccarello played over 30 games with the affiliate Whale Hockey Club in the AHL. At the AHL level, the Player has demonstrated his offensive ability in the North

American game, averaging close to a point per game (see figure 3 below). The table below shows the Player’s offensive production in the AHL.

15 Ibid. Page | 6

Table 3: AHL Offensive Production Season GP G A PTS PIM +/- 2010-11 36 13 16 29 16 2 2011-12 37 12 24 36 22 5

[14] Aside from the NHL, the AHL is not the only professional league in which the Player has produced impressive offensive numbers. Zuccarello has put up impressive offensive numbers, especially in the AHL and SEL. He has produced near a point per game in the former and over a point per game in the latter 16 .

1.500 Point Production outside the NHL 1.156 1.000 0.893 0.627 0.500

0.000 AHL KHL SEL

Figure 3: Professional hockey PPG

[15] While playing with MODO in the Swedish professional league, Zuccarello’s impressive

2009-10 season led him to win the Guldhjälmen award as the SEL’s most valuable player 17 . That

season he led the league in scoring with 64 points in 55 games (1.16 PPG) 18 . Year-by-year production in European and Russian professional leagues is shown in the table below.

Table 4: Across-the-Atlantic Hockey Offensive Numbers 19 League Season GP G A PTS PIM +/- SEL 2008-2009 35 12 28 40 38 - SEL 2009-2010 55 23 41 64 62 - KHL 2011-2012 44 11 17 28 38 -

16 Supra note 8. 17 See http://rangers.nhl.com/club/news.htm?id=679173 . 18 Ibid . 19 Supra note 16. Page | 7

[16] Zuccarello also has experience representing his country at the high-pressure international stage. He has played amongst the world’s best prospects, representing Norway at the Under-18 tournament in 2003-04, 2004-05. Both years Zuccarello also represented Norway at the World

Junior 18-year old tournament (WJ18). Following these, he skated for Norway at the World

Junior Championships (WJC) twice. He has also worn the jersey for Norway at the World

Championships (WC) and in the 2010 Winter Olympics. His international stats are in table 5 below. His PPG on the international stage is 0.541, above his NHL rate.

Table 4: International Hockey Offensive Numbers 20 Tournament Year GP G A PTS PPG U-18 2003-04 24 23 14 37 1.54 U-18 2004-05 12 11 28 29 2.42 WJ18 2003-04 6 0 2 2 0.33 WJ18 2004-05 5 2 3 5 1.00 WJC 2005-06 6 0 2 2 0.33 WJC 2006-07 5 2 5 7 1.40 WC 2007-08 7 1 0 1 0.14 WC 2008-09 6 3 0 3 0.50 WC 2009-10 6 3 1 4 0.67 2010 Olympics 2009-10 4 1 2 3 0.75 Total N/A 81 46 57 93 1.15

[17] Finally, Zuccarello has the ability to play a significant amount of hockey in any given season. He is a reliable player for 60 games per year and rarely gets injured. The season prior to coming to North America (2009-10), he played 65 games between the SEL, World

Championships and the Olympics 21 . During the 2010-11 season he played 79 games between the

NHL and AHL 22 . In the 2011-12 season, he played only 47 due to an injury, owing to which he missed the end of the season. In the lockout 2012-13 season, Zuccarello played 78 games

20 Supra note 16. 21 Supra note 16 . 22 Ibid. Page | 8 between the NHL and KHL. He has the endurance and stamina to play night in and night out for the full 82-game NHL schedule.

6. CONCLUSION

[18] While Zuccarello does not bring a body the size of Spaling to the Club, he does bring a mindful ability to prevent opposition goals and potent ability to make plays and help the Rangers put pucks in the back of the net. Evidence has demonstrated that Zuccarello is a much more offensive player than Spaling in the NHL, and does a better job and preventing goals. In short,

Zuccarello helps the Rangers win games, both in the regular season and the playoffs. Because of this, he was one of the key RFA’s the Club needed to resign.23

[19] Zuccarello’s significant offensive abilities and greater professional experience demand a

premium to Cam Atkinson. Atkinson is paid an identical $1,150,000 salary. Compared to Cam

Atkinson, it has been shown Zuccarello is a much more valuable player to his team and

contributes to winning. Zuccarello has far greater professional and high-level experience, owing

to his time playing in the KHL, AHL and Swedish SEL.

[20] Mats Zuccarello’s experience, offensive production and value to his team have all been

underestimated. This has been reflected in his salary. Based on the analysis of the Player’s

Platform Year performance and career performance against submitted comparables, along with

additional considerations, it is evident fair compensation lies somewhere between $1.15M and

$1.5M. The player respectfully ask the arbitrator find a reasonable medium near $1.3M.

23 Supra note 7 Page | 9