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2012 HOCKEY ARBITRATION COMPETITION OF CANADA

Ondrej Pavelec v. (NHL)

SUBMISSION ON BEHALF OF WINNIPEG JETS HOCKEY CLUB

TEAM # 8

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INDEX

A. INTRODUCTION AND REQUEST FOR HEARING ……………………………….…...2

B. A PROFILE OF ONDREJ PAVELEC……………………………………………….……3-4

C. STATISTICS…………………………………………………………………………….…4-5

D. SELECTION OF COMPARABLE PLAYERS……………………………………………5

E. COREY SCHNEIDER (EXHIBIT 1)………………………………………………………5-6

F. TUUKKA RASK (EXHIBIT 2)……………………………………………………….……6-7

G. DEVAN DUBNYKE (EXHIBIT 3)……………………………………………………...…7

H. (EXHIBIT 4)………………………………………………………….….7

I. (EXHIBIT 5)………………………………………………….….8

J. COREY CRAWFORD (EXHIBIT 6)…………………………………………………..…....8

K. (EXHIBIT 7)………………………………………………..……...9

L. OVERVIEW OF THE COMPARABLES……………………………………….…………9-10

M. CONCLUSION…………………………………………………………………………….10

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A. INTRODUCTION AND REQUEST FOR HEARING

This brief analyzes the assets and contributions of goalkeeper Ondrej Pavelec (“Pavelec”) to be reflected in his 2012 contract with the Winnipeg Jets Hockey Club (the “Club”). The

National Hockey League (“NHL”) Collective Bargaining Agreement (“CBA”) between NHL

Clubs and the NHL Players’ Association set the criteria to be considered in this arbitration hearing.

Under Article 12, Part 9 subsections g (ii) of the CBA, an arbitration panel will use as criteria (A) the overall performance of the player in the previous season or seasons; (B) the number of games played by the player, his injuries or illnesses during the preceding seasons; (C) the length of service of the Player in the NHL and/or with the club; (D) the overall contribution of the Player to the competitive success or failure of his club in the preceding season; (E) any special qualities of leadership or public appeal not inconsistent with the fulfillment of his responsibilities as a playing member of his team; (F) the overall performance in the previous season or seasons of any player(s) who is alleged to be comparable to the party player whose salary is in dispute; and (G) the compensation of any player(s) who is alleged to be comparable to the party player.1 Any evidence may be submitted in this brief or at argument as long as it is relevant to the above listed criteria, and such weight shall be assigned to the above criteria, as the arbitration panel deems appropriate. The arbitration panel shall not consider the financial position of the Club, press comments and press material on the performance of Pavelec, and any offers made by either party prior to the arbitration hearing.2

The Winnipeg Jets Hockey Club respectfully submits this brief in support of its argument that Pavelec should receive a salary of no more than $3,500,000.

1 NHL CBA - Article 12, Part 9 subsections g (ii) 2 NHL CBA - Article 12, Part 9 subsections g (iii)

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B. A PROFILE OF ONDREJ PAVELEC

Ondrej Pavelec, age 25, was born August 31, 1987 in the . He is 6’3, 220 pounds. He catches left and plays for the Winnipeg Jets. He was drafted in the 2nd round, 41st overall by the in the 2005 NHL Entry Draft. 3 Since being drafted,

Mr. Pavelec has been inconsistent in NHL appearances and had been reassigned to the Atlanta

Thrasher’s farm team on multiple occasions throughout his NHL career. 4Since his first game being called up to the NHL on October 20, 2007, Pavelec has only played in 187 NHL games in

5 seasons and has no NHL playoff experience.5

On October 8, 2010, Pavelec collapsed and lost consciousness during a game against the

Washington Capitals while there was a break in play at 2:25 into the first period. He was taken off the ice on a stretcher and taken to the hospital. He regained consciousness while at the hospital. It was determined after testing by doctors that he suffered a type of fainting spell and that he received a concussion and lost consciousness after his head hit the ice. He was released from the hospital shortly after. This was the opening game of the Atlanta Thrashers’ season when

Pavelec fainted. This is indicative of an underlying condition or extreme nervousness in big games. Pavelec has not played in an NHL playoff game and it is unpredictable as to how he will respond to the pressure of playoffs.

Although loved by Winnipeg Jets fans for his flashy style of play, Pavelec has recently tarnished his personal reputation and the reputation of his team. This summer, he was charged in the Czech Republic with impaired driving in connection with an incident in May. National news reports claim that Pavelec had a blood alcohol level of 0.2 — more than twice the legal limit in

3 NHL.com - http://www.nhl.com/ice/player.htm?id=8471715#&navid=nhl-search 4 Id. 5 Id. Page 4

Manitoba — when his BMW rear-ended another vehicle. No one was reported to be injured. 6 He pleaded guilty on June 12, 2012.

C. STATISTICS

2011/2012 Season Statistics: Player Team GP W L GA GAA SA SV% Pavelec WPG 68 29 28 191 2.91 1845 .9067

Pavelec’s 29 wins render him tied for 19th in the league for wins (W) and his 28 losses

(L) render him second in the league for most losses in a season. His 191 goals against (GA) are the most any goalkeeper let in this season. He is 66th out of 89 goalkeepers for lowest goals against average (GAA). However, goals against average is largely a team statistic and thus it is not the focus as save percentage is much more closely linked to the individual goaltender. His save percentage renders him 60th (SV%). While it can be said that the Winnipeg Jets enjoyed a measure of success in their first season back in the NHL, this success cannot be attributed to

Pavelec. His statistics are average and the Jets’ 12th ranking 221 goals is better than seven of the

NHL teams who made the playoffs. 8 It is clear that a lack of scoring is not what kept the Jets out of the playoffs and in 11th place in the Eastern Conference. 9 Of the top 60 goalies who played the most games, Pavelec ranked a mere 39th in save percentage. 10 Ultimately, there is nothing exceptional about Pavelec’s platform year numbers.

Despite very average statistics last season, 2010/2011's numbers do help Pavelec's case for being a decent starting goaltender, but only his even strength save percentage of .917%11.

6 http://www.cbc.ca/news/canada/manitoba/story/2012/07/16/mb-onjrej-pavelec-jets-impaired-driving.html 7 NHL.com - http://www.nhl.com/ice/player.htm?id=8471715#&navid=nhl-search 8 NHL.com - http://www.nhl.com/ice/standings.htm?season=20112012&type=CON 9 Id. 10 NHL.com 11 NHL.com Page 5

However, it's just one season of one good-looking stat and this one stat is well below the season average among goalies who played 25 games or more.12 His statistics and the following selection of comparable players demonstrate that Mr. Pavelec deserves a salary more in line with the

$3,500,000 mark.

D. SELECTION OF COMPARABLE PLAYERS

At this point we would like to compare Pavelec’s 2011/2012 platform numbers to those of other goalies in the same age range and with similar totals. We will consider the following comparable players:

Player Team Age 2011/2012 Salary Ondrej Pavelec WIN 24 3,900,000

Player Team Age 2011/2012 Salary Contract Length Cory Schneider VAN 26 3,500,000 3 Tuukka Rask BOS 25 3,500,000 1 Devan Dubnyk EDM 26 3,250,000 2 Steve Mason CLB 24 3,200,000 2 Semyon Varlamov COL 24 3,000,000 3 Corey Crawford CHI 27 2,250,000 3 Michal Neuvirth WSH 24 1,150,00013 2

E. COREY SCHNEIDER (EXHIBIT 1)

Corey Schneider is a 26 year old goalkeeper for the Canucks with playoff experience. Schneider’s SV% is better and his goals against average is much better. Despite playing in only 33 games, he is ranked 27th in the league in wins. He is also ranked second in save percentage and third in goals against average. These are impressive numbers. His career playoff numbers are also impressive because in eight games his save percentage is .940 and is

GAA is 1.91. Schneider also plays for a team whose fans and media are known for being hard on

12 NHL.com < http://www.nhl.com/ice/playerstats.htm?season=20102011&gameType=2&team=&position= G&country=&status=&viewName=summary> 13 Capgeek.com Page 6

goalies and have even dubbed the Canucks the “goalie graveyard.” It is safe to say, based on his numbers and the environment that he is playing in, that Schneider can handle pressure and is a safe bet for the future of any team. It is questionable that Schneider makes $3,500,000 and that

Pavelec is asking for $3,900,000+. Any way you look at the statistics, Schneider is the better goalie and Pavelec should not be making more than him, especially $400,000 more.

Career Comparison: Player GP W L GA SA SV% GAA Schneider 68 38 17 136 1880 .928 2.24 Pavelec 187 70 79 519 5585 .907 2.99

Platform Year Comparison: Player GP W L GA SA SV% GAA Pavelec 68 29 28 191 1845 .906 2.9114 Schneider 33 20 8 60 945 .936 1.9615

F. TUUKKA RASK (EXHIBIT 2)

Tuukka Rask is a 25 year old goalie for the with playoff experience.

Rask’s save percentage and goals against average are better throughout his career and during the platform year in comparison to Pavelec. He also has 13 games of playoff experience.

Career Comparison: Player GP W L GA SA SV% GAA Rask 102 47 35 209 2831 .926 2.20 Pavelec 187 70 79 519 5585 .907 2.99

Platform Year Comparison: Player GP W L GA SA SV% GAA Pavelec 68 29 28 191 1845 .906 2.91 Rask 23 11 8 44 621 .929 2.0516

14 NHL.com - http://www.nhl.com/ice/player.htm?id=8471715#&navid=nhl-search 15 NHL.com - http://www.nhl.com/ice/player.htm?id=8471239#&navid=nhl-search 16 NHL.com - http://www.nhl.com/ice/player.htm?id=8471695#&navid=nhl-search Page 7

G. DEVAN DUBNYK (EXHIBIT 3)

Devan Dubnyk is a 26 year old goalie for the , the second last place team in the league for the 2011/2012 season. Dubnyk, playing on the second last place team, has a better save percentage and better goals against average than Pavelec. He makes $3, 250,000.

There is nothing that Pavelec has done to support him getting an additional $650,000 over

Dubnyk’s salary.

Career Comparison: Player GP W L GA SA SV% GAA Dubnyk 101 36 43 275 3062 .910 2.85 Pavelec 187 70 79 519 5585 .907 2.99

Platform Year Comparison: Player GP W L GA SA SV% GAA Pavelec 68 29 28 191 1845 .906 2.91 Dubnyk 47 20 20 118 1380 .914 2.6717

H. STEVE MASON (EXHIBIT 4)

Steve Mason is a 24 year old goalie for the , the last place team in the NHL for the 2011/2012 season. In the years that Mason has played for Columbus, the team has finished 16th, 27th, 24th, and 30th. In the years that Pavelec played for the Thrashers/Jets, the team has finished 28th, 27th, 23rd, 25th and 22nd. These are comparably poor teams and both goalies have put up comparably poor numbers. We must question the fact that Mason makes

$3,200,000 while Pavelec is asking for well above that.

Career Comparison: Player GP W L GA SA SV% GAA Mason 219 93 93 599 6207 .904 2.89 Pavelec 187 70 79 519 5585 .907 2.99

17 NHL.com - http://www.nhl.com/ice/player.htm?id=8471227#&navid=nhl-search Page 8

I. SEMYON VARLAMOV (EXHIBIT 5)

Semyon Varlamov is a 24 year old goalie for the with 19 games of playoff experience. His GAA and his SV% is better than Pavelec’s numbers. He played 15 games less than Pavelec this season and almost had just as many wins. He will make $3,000,000, which once again causes questions around Pavalec’s high salary request.

Career Comparison: Player GP W L GA SA SV% GAA Varlamov 112 56 37 272 3200 .915 2.48 Pavelec 187 70 79 519 5585 .907 2.99

Platform Year Comparison: Player GP W L GA SA SV% GAA Pavelec 68 29 28 191 1845 .906 2.91 Varlamov 53 26 24 136 1564 .913 2.5918

J. COREY CRAWFORD (EXHIBIT 6)

Crawford is a 27 year old goalie for the with playoff experience. He has 64 wins in 122 games whereas Pavelec has just 6 more career wins in 65 more games played.

His career save percentage and goals against average is better than Pavelec’s numbers and their platform year numbers are very similar. Crawford makes $2,250,000. Pavelec should certainly not be making $1,650,000 more than Crawford.

Career Comparison: Player GP W L GA SA SV% GAA Crawford 122 64 38 290 3240 .910 2.51 Pavelec 187 70 79 519 5585 .907 2.99

Platform Year Comparison: Player GP W L GA SA SV% GAA Pavelec 68 29 28 191 1845 .906 2.91 Crawford 57 30 17 146 1507 .903 2.7219

18 NHL.com - http://www.nhl.com/ice/player.htm?id=8473575#&navid=nhl-search 19 NHL.com - http://www.nhl.com/ice/player.htm?id=8470645#&navid=nhl-search Page 9

K. MICHAL NEUVIRTH (EXHIBIT 7)

Michal Neuvirth is a 24 year old goalie with the with playoff experience. He has a better career save percentage and goals against average and has very similar platform year numbers. He makes $1,150,000, a whopping $2,750,000 less than what Pavelec is asking for.

Career Comparison: Player GP W L GA SA SV% GAA Neuvirth 108 51 30 256 2825 .909 2.65 Pavelec 187 70 79 519 5585 .907 2.99

Platform Year Comparison: Player GP W L GA SA SV% GAA Pavelec 68 29 28 191 1845 .906 2.91 Neuvirth 38 13 13 95 976 .903 2.8220

L. OVERVIEW OF THE COMPARABLES

Rask has played 102 NHL games, posting a 0.926 SV%. Schneider has played 68 games, with a 0.928 SV%. Dubnyk has played 101 games with a 0.910 SV%. Pavelec has played 187 games, with a 0.907 SV%. The only thing that Pavelec brings to the table that the others don't is that he has played as many games as a typical starting goalie in the NHL whereas the others are in a tandem goalkeeping position with another goalie and split games or are in a transitioning role from backup goalie to becoming a starter. Despite this, Pavelec has no playoff experience and there is no reason to believe that Pavelec is better than any of the comparable players. For this platform year, out of all the aforementioned players, Pavelec has the worst goals against average and is beaten by four other goalies in save percentage. It is ludicrous that he is asking for so much more money than any of the comparable goalie. Pavelec is and always has been a

20NHL.com - http://www.nhl.com/ice/player.htm?id=8473607#&navid=nhl-search Page 10

below-average goaltender. His best-ever season was 2010-11, when his even strength save percentage was 25th-best in the league.21

2011/2012 Comparables’ Statistics Player Team GP W L SA GA GAA Sv Sv% Pavelec WIN 68 29 28 2036 191 2.91 1845 .906 Schneider VAN 33 20 8 945 60 1.96 885 .937 Rask BOS 23 11 8 621 44 2.05 577 .929 Dubnyk EDM 47 20 20 1380 118 2.67 1262 .914 Mason CLB 46 16 26 1355 143 3.39 1212 .894 Varlamov COL 53 26 24 1564 136 2.59 1428 .913 Crawford CHI 57 30 17 1507 146 2.72 1361 .903 Neuvirth WSH 38 13 13 976 95 2.82 976 .903

M. CONCLUSION

The Jets are excited to have Ondrej Pavelec on their team. The club is looking forward to the impact he will have during the 2012/2013 season. However, the Jets are insistent on paying

Mr. Pavelec fair value for his services. Pavelec should be compensated for his past performance, not his future potential. Although Pavelec has shown potential, it is easy to become enamoured with the player he could be and not accept the player that he is. The Jets believe that $3,500,000 is a fair and accurate salary for Mr. Pavelec. As shown with comparative salaries, goalkeepers who have had better careers and better platform seasons than Pavelec are earning less than the amount that he is asking for. $3,500,000 is a more accurate and reasonable amount than

$3,900,000. The Jets respectfully request that the Arbitration Panel agree with this assertion and find that the Club’s offer of $3,500,000 is fair compensation for Mr. Pavelec.

21 NHL.com - http://www.nhl.com/ice/playerstats.htm?season=20102011&gameType=2&team=&position= G&country=&status=&viewName=summary