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IN THE MATTER OF A SALARY ARBITRATION

BETWEEN:

DERICK BRASSARD

-AND-

NEW YORK RANGERS

BEFORE: NATIONAL ACADEMY OF ARBITRATORS’

BRIEF IN SUPPORT OF A COMPENSATION REQUEST FOR THE PLAYER

Team 32 ’s Representation

TABLE OF CONTENTS

I. INTRODUCTION…………………………………………….…....…………3

II. OVERALL ASSESSMENT OF THE PLAYER ………...…...…….………...3

III. OF GAMES PLAYED AND INJURY HISTORY……………….4

IV. CAREER-TO-PLATFORM STATISTICS……………………..……....…….4

V. OVERALL CONTRIBUTION TO THE CLUB………………...……………5

VI. COMPARABLE PLAYERS………………………………………….………6

a. Mr. Brassard compared to Mr. Gagner………..…………………………..6

b. Mr. Brassard compared to Mr. Ennis...….……………………………...... 8

VII. CONCLUSION……………………………………………………..………..10

2 I. INTRODUCTION

This brief will provide a framework that is capable of awarding appropriate value to Mr. Brassard’s offensive contributions to the . In this context, Mr.

Brassard’s valuation will consider: overall performance, number of games played, injury history, length of service, and his overall contributions to the Rangers. The salaries of the comparable forwards will frame a narrow range to assign Mr. Brassard’s value.

On behalf of the Player, Mr. Brassard, we respectfully submit that $5.2 million for one year is an accurate and equitable assessment of his value to the Rangers.

II. OVERALL ASSESSMENT OF THE PLAYER

Mr. Brassard is a 27 year-old, left-handed from Hull, Quebec. Mr. Brassard is

6’1”, 202 lbs., as of the beginning of the 2013-2014 NHL season. In the 2006 NHL Entry

Draft (“Entry Draft”) the Columbus Jackets (“the Blue Jackets”) selected Mr.

Brassard, in the first round, 6th overall1. The Player’s high selection in the Entry Draft is the partial result of the high value teams place on his style of play.

Mr. Brassard has excellent on ice vision and play making ability. He has great drive towards the net, and an even better wrist . He is capable of playing on the first or second line for the Rangers as his ability to create scoring chances is well documented.

Prior to his time with the New York Rangers Mr. Brassard spent six years with the

Columbus Blue Jackets. Having now completed eight NHL seasons Mr. Brassard is in the prime of his career and brings a great deal of experience to the New York Rangers.

1 , statistics, online:

3 III. NUMBER OF GAMES PLAYED AND INJURY HISTORY

Mr. Brassard has played eight seasons in the NHL accumulating 403 games2. During

the 2007-2008 season, Mr. Brassard split his playing time between the Blue Jackets and

their (“AHL”) affiliate.

IV. CAREER-TO-PLATFORM STATISTICS

Mr. Brassard recorded career highs in his 2010-2011 season with 17 goals, 30

assists for a total of 47 points, which equates to 0.64 Pts/G in 74 games played.3 While he

failed to surpass this performance since 2010-2011, he has remained consistent by

surpassing his 17 goals in his platform season scoring 18 this past season4.

Mr. Brassard’s career scoring statistics suggest that he is a proven and balanced

point producer. The theme of offensive consistency is apparent throughout his career and

little weight should be placed on his early career (see Table 1). Moreover, Mr. Brassard’s

career-to-platform statistics speak to the reliability of his statistical pace during his

platform-season.

Table 1: Derick Brassard’s Career Performance5

Season GP G A P +/- PIM PPG SHG GWG S TOI/ game 07-08 17 1 1 2 -4 6 0 0 0 13 9:03 08-09 31 10 15 25 12 17 3 0 1 59 14:25 09-10 79 9 27 36 -17 48 4 0 1 125 14:56 10-11 74 17 30 47 -11 55 6 0 3 183 17:01 11-12 74 14 27 41 -20 42 5 0 3 125 16:20 12-13 47 12 17 29 1 16 3 0 1 88 16:31 /16:3

2 Ibid. 3 Ibid. 4 Ibid. 5 5 National Hockey League online: .

4 8 13-14 81 18 27 45 2 46 7 0 4 159 15:47 TOTAL 403 81 144 225 -37 230 28 0 12 752 ------

V. PLATFORM-SEASON STATISTICS

Mr. Brassard played 81 games in his platform-season, which is a sufficient sample

to gauge his contributions to the Ranger’s and to determine an appropriate salary. Mr.

Brassard scored 18 goals and 27 assists in the 2013-2014 season, which resulted in 0.56

points per game or 0.22 goals per game6.

VI. OVERALL CONTRIBUTION TO THE CLUB

Mr. Brassard played as the second line center for the Rangers in his platform season,

which demonstrates his importance to the club7. Mr. Brassard contributed 9 goals in the

final 26 games of the 2013-2014 season to help clinch 5th place in the Eastern conference.

Mr. Brassard finished 4th in points on an offensively talented New York Rangers team. It

is highly valued when a player, playing against top players has the ability to produce both

offensively and defensively and Mr. Brassard’s plus/minus statistic of +2 demonstrates

that he has the ability to excel in this area8.

Mr. Brassard’s ice time was consistent throughout the season averaging 15:47

minutes per game demonstrating that the player was trusted in crucial situations of the

game9. Mr. Brassard was a key contributor on the Rangers power play which finished in

the top half of the league converting on 18.2% of their power plays10 by contributing 7

goals and 11 assists and averaging 2:31 minutes of power play time per game in the

6 Supra, note 2. 7 thehockeynews.com, http://forecaster.thehockeynews.com/hockeynews/hockey/depthchart.php?NYR 8 Supra, note 2. 9 Ibid. 10 Ibid.

5 regular season11.

Mr. Brassard was a key component in the Rangers playoff success. Since joining the

club in the 2012-2013 season, he has played a total of 35 playoff games for the Rangers,

scoring 8 goals and 24 points12. In the playoffs, Mr. Brassard has scored 3 game winning

goals, which indicates that in high-pressure situations Mr. Brassard performs well13.

VII. COMPARABLE PLAYERS

A.

Table 2: Sam Gagner’s Career Performance14

Season GP G A P +/- PIM PPG SHG GWG S TOI/ game 07-08 79 13 36 49 -21 23 4 0 1 135 15:40 08-09 76 16 25 41 -1 51 6 0 1 156 16:45 09-10 68 15 26 41 -8 33 6 0 1 170 16:17 10-11 68 15 27 42 -17 37 3 1 2 138 17:44 11-12 75 18 29 47 5 36 6 0 0 149 17:10 12-13 48 14 24 38 -6 23 4 0 1 113 19:24 TOTALS 414 91 167 258 -48 203 29 1 6 861 ------

In 2013, Sam Gagner signed a three-year contract with the

worth $4.8 million per year.15 At the time of the signing, Mr. Gagner was a 24-year-old

with the Oilers. He had six years of NHL experience and no playoff experience.

He played in 414 NHL games, scoring 258 points, and at the time, had a PPG career

statistic of 0.62, which is slightly higher then Mr. Brassard’s 0.56 career statistic.

11 Ibid. 12 Ibid. 13 Ibid. 14 www.nhl.com 15 http://www.capgeek.com/player/23

6 In his platform season, Mr. Gagner played 48 games, scoring 38 points (14 goals and 24 assists) and had a PPG statistic of 0.79. That is significantly higher then Mr.

Brassard’s 0.56. However, Mr. Gagner played in a shortened season where he had adequate rest. Mr. Brassard played a full 81 game season and participated in a playoff run to the Final. He also played four minutes less per game then Mr. Gagner. As mentioned earlier, Mr. Gagner has zero playoff experience, whereas Mr. Brassard has 35 games worth of experience where he scored 24 points during those games. There is great value in playoff experience, and play in the Stanley Cup Final is even more important.

During his platform season, Mr. Gagner had an even strength production ranking of 79th in the NHL, but faced average competition. In the East, Mr. Brassard regularly faced excellent competition.

Mr. Gagner has a plus minus in his platform season of -6, whereas Mr. Brassard has one of +2. It is evident that Mr. Brassard is more defensively responsible then Mr.

Gagner is. In his platform year, Mr. Gagner had an average of 2.29 giveaways per game, whereas Mr. Brassard, in a longer season, had an average of 1.31 giveaways per game. 16

Both players had similar takeaway statistics in their platform years. It is clear that Mr.

Brassard is stronger on the puck. Mr. Gagner was useful on the powerplay but gave up too many pucks at even strength.

Mr. Brassard is also only improving in his play on the ice, whereas Mr. Gagner seems to be at a stalemate. Mr. Gagner is already one of the top centremen on his team, with the most icetime on the Oilers in his platform year and second in points. Mr.

Brassard, on the other hand, is only improving and is working his way towards one of the

16 http://www.sportingcharts.com/nhl/stats/player-giveaways-statistic/2012/

7 top centre spots on a very talented New York Rangers team. In his rookie year, Mr.

Brassard only played just over nine minutes, and is now playing on average 15:47 a

night. In his platform year, he was fourth among Rangers forwards in ice time. Mr.

Brassard has a great opportunity to move up on the team whereas Mr. Gagner can’t go

much further then he has.

When Mr. Brassard joined the New York Rangers, they had two years of great

success, making the playoffs both times. When Mr. Gagner played for the Oilers, they did

not finish higher then 18th in the regular season and that was in the season that he had the

least amount of ice time (2007-2008).

In his platform year, Mr. Gagner did not score consistently. Mr. Brassard scored

very consistently throughout his entire season. That is evident from his career and

platform season PPG statistic of 0.56. He can be relied upon to score no matter what

situation he is in. Mr. Gagner scored the majority of his points in the middle half of his

shortened season (February-March). Over the same period of time in a shortened season,

Mr. Brassard scored 7 points in February 8 in March, and 11 in April. He assisted in a big

playoff push for his team.

B. TYLER ENNIS

Table 3: Tyler Ennis’s Career Statistics17

Season GP G A P +/- PIM PPG SHG GWG S TOI/ game 09-10 10 3 6 9 1 6 0 0 0 23 15:20 10-11 82 20 29 49 0 30 5 0 1 210 15:40 11-12 48 15 19 34 11 14 2 0 1 82 16:09

17 www.nhl.com

8 12-13 47 10 21 31 -14 16 2 0 0 108 17:52 13-14 80 21 22 43 -25 42 6 0 0 210 18:51 TOTALS 267 69 97 166 -27 108 15 0 2 633 ------

In 2014, Tyler Ennis signed a five-year contract with the for an

average annual salary of $4.6 million per year, with an actual salary of over $7 million in

the first year of the contract.18 Mr. Ennis is a 25-year-old centre with the Sabres. He has

five years of professional hockey experience and two years worth of playoff experience.

He has played in 267 games, scoring 166 points, and has a PPG career statistic of 0.62,

which is similar to Mr. Brassard’s 0.56.

In his platform season, Mr. Ennis played 80 games, scoring 21 goals and 22

assists, and was ranked 125th in point production in the NHL, compared to Mr. Brassard’s

45 points and 111th ranking in the NHL. He had a PPG statistic of 0.53 in that season,

significantly lower then his career average of 0.62. In his platform season, Mr. Brassard

was consistent and had a 0.56 PPG career statistic and platform year statistic. Mr.

Brassard played one more game then Mr. Ennis but managed to score at a higher pace

while also playing approximately three minutes less a game. Mr. Ennis has two years of

playoff experience, playing in 13 games. During those games he scored 3 goals and 5

assists. During the 2012 playoffs, when Mr. Brassard played one less game (12), he

scored 13 points, 3 of which were goals. Mr. Ennis has never made it past the first round

of the playoffs. Mr. Brassard has done that twice.

18 http://www.capgeek.com/player/1572

9 Mr. Ennis had a plus minus of -25 in his platform season, while Mr. Brassard had one of +2. It can be easily seen that the more time Mr. Ennis plays, the worse his plus minus gets.

In his rookie year, Mr. Ennis played on average 15:20 minutes a night, whereas

Mr. Brassard started off playing nine minutes a night. From there, Mr. Brassard moved to just under 16 minutes a night. Mr. Ennis is currently playing on average 18:51 a night.

That puts him second on the Sabres in total ice time per game, whereas Mr. Brassard was

12th on the Rangers in total ice time. Mr. Brassard quite clearly has room to grow, have more ice time, and show off his skills.

Mr. Brassard had even, relatively consistent scoring throughout his platform season. Mr. Ennis scored consistently through 2/3 of his season and towards the end, really trailed off and saw a sharp reduction in his scoring. His team was far out of the playoffs but a strong finish to the season and an attempted push to the playoffs is what teams need from their top players.

VIII. CONCLUSION

This brief has assessed Mr. Brassard’s value with respect to his overall career performance, injury history, plus/minus statistics, his overall contribution to the club, and identified two comparable players to best frame his current market value. The head-to- head comparisons demonstrate the appropriate selection of comparable players, which to frame the current market value for Mr. Brassard. In consideration of the totality of Mr.

Brassard’s contributions leading up to this arbitration, it is respectfully submitted that the compensation request of $5,200,000 for one year be granted for being an accurate assessment of what Mr. Brassard is worth for the 2014-2015 season.

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