IN THE MATTER OF SALARY ARBITRATION

BETWEEN:

CARL GUNNARSSON

(“THE PLAYER”)

AND

THE

(“THE CLUB”)

THE CLUB’S BRIEF

TEAM 11

Counsel for “THE CLUB”

Table Of Contents

I. Introduction: pg.1

II. Player Assessment: Carl Gunnarsson: pg. 1

a) Player Overview: pg.1

b) Pre-NHL Career: pg.2

c) NHL Career pg.2

i) Overall Performance in Previous Seasons and Statistics in the NHL: pg.2

ii) Games Played/ Injury History: pg.3

iii) The length of Service of the player in the NHL or with the Club: pg.3

iv) The overall contribution to his club in the preceding season: pg.4

III. Player Comparison: Gunnarsson compared to Quincey and Stralman: pg.5

a) Criteria for Selecting Comparable Players: pg.5

b) Gunnarsson v Quincey: Why Gunnarsson does not quite match up: pg.5

c) Gunnarsson v Stralman: A Better Match: pg.7

IV. Conclusion: pg.8

1

I. Introduction

The following brief has been prepared on behalf of the Toronto Maple Leafs (The Club) with respect to its salary arbitration proceedings with defenceman Carl Gunnarsson. After a general overview of Gunnarsson and his pre-NHL pro hockey career, this brief will consider the following categories of evidence, pursuant to Article 12 of the current CBA, in order to assess Mr. Gunnarsson’s value as an NHL player: 1) the overall performance of Mr. Gunnarsson in previous NHL seasons with particular emphasis on his offensive and defensive statistics; 2) The number of games played and any injuries or illnesses; 3) length of service in the League and/or with the Club and 4) the overall contribution of the

Player to the competitive success or failure of his Club in the preceding season. The brief will then consider Gunnarsson’s performance as an NHL player in contrast with two comparable players: Kyle Quincey and Anton Stralman. To conclude, the brief takes the position that any award of salary granted to Mr. Gunnarsson should be $2,737,500 (the midpoint between Quincey and Stralman’s annual salary) or less, on the argument that

Gunnarsson as of his year of eligibility is more akin to Stralman than to Quincey.

II. Player Assessment: Carl Gunnarsson a) Player Overview

Carl Gunnarsson was a 7th round draft pick of the Toronto Maple Leafs (194th overall) in the 2007 NHL Entry Draft. Gunnarsson is 6’2” and weighs 196 pounds.1 In 2012-13

Gunnarsson played 37 of 48 games in the shortened NHL season, scoring 1 , adding

1 http://www.hockey-reference.com/players/g/gunnaca01.html 2

14 assists and finishing with a +/- of 5 on the season.2 In seven playoffs games last season, Gunnarsson contributed one assist and finished with a +/- of -7.3 b) Pre-NHL Career

Prior to entering the NHL, Gunnarsson played junior hockey in Sweden and three seasons in the Swedish Elite League with Linkopings HC (2006/07, 2007/08, 2008/09).

Gunnarson posted points per game averages of 0.13, 0.17 and 0.30 respectively during regular season play and in 38 playoff games with Linkopings contributed 9 assists, zero goals and an average of 0.24 points per game.4 Overall, Gunnarson averaged 0.22 points per game during his time with Linkopings HC. c) NHL Career

i) Overall Performance in Previous Seasons and Statistics in the NHL

Season Age Tm Lg GP G A PTS GC +/- PIM EV PP SH GW EV SH PP S S% TOI ATOI

2009-10 23 TOR NHL 43 3 12 15 5 8 10 3 0 0 0 9 1 2 45 6.7 922 21:26

2010-11 24 TOR NHL 68 4 16 20 7 -2 14 3 1 0 1 13 0 3 69 5.8 1240 18:15

2011-12 25 TOR NHL 76 4 15 19 6 -9 20 4 0 0 0 9 0 6 89 4.5 1649 21:42

2012-13 26 TOR NHL 37 1 14 15 4 5 14 1 0 0 0 14 0 0 28 3.6 787 21:17 Career NHL 224 12 57 69 22 2 58 11 1 0 1 45 1 11 231 5.2 4599 20:32

5 Gunnarson’s regular season statistics demonstrate that he has not contributed offensively from the blue line as top defenceman. He has never scored more than four goals in a season. In his platform year Gunnarsson had his strongest offensive output averaging

0.41 points per game compared to his overall regular season average of 0.31.6

Gunnarsson was a +5 on a much improved Leafs team which finished with 12 more goals

2 Ibid. 3 Ibid. 4 http://mapleleafs.nhl.com/club/player.htm?id=8474125 5 Supra note 1. 6 Ibid. 3 for than goals against.7 Yet in Gunnarsson’s two seasons prior to his platform year, in which he played 68 and 76 games respectively, he went a combined -11 with points per game averages of 0.29 and 0.25.8 The statistics show that the in the two seasons in which

Gunnarsson played in the better part of a full NHL schedule, his offensive output and defensive statistics were much worse than in 2008-09 and in his platform year 2012-13.

The Club accordingly takes the position that although he has shown potential,

Gunnarsson has not yet shown he can put together a full season of hockey with the kind of statistical success he showed in 2008-09 and 2012-13.

ii) Games Played/ Injury History

Gunnarsson has played a total of 224 games in the NHL during four seasons. In 2009-10,

Gunnarsson missed 22 games with an elbow injury (Dec.1- Jan. 12) and in 2011-12,

Gunnarsson missed 7 games from three different injuries.9 In his platform year

Gunnarsson missed 11 games out of 48 (23% of his team’s games) due to several injuries.10. In a full 82 game schedule this would amount to missing 19 games. Given Mr.

Gunnarsson’s persistent tendency to suffer injuries, notable in his platform year, the Club takes the position that Gunnarsson’s injury history is a significant if not major worry.

iii) The length of Service of the player in the NHL or with the Club

Gunnnarsson has played the better part of four seasons in the NHL all with the Toronto

Maple Leafs. Gunnarsson signed an entry-level contract in 2009 which kept him under

7 http://www.nhl.com/ice/standings.htm?season=20122013&type=DIV 8 Supra note 1. 9 http://mapleleafs.nhl.com/club/player.htm?id=8474125&view=bio 10 http://mapleleafs.nhl.com/club/player.htm?id=8474125&view=notes 4 contract for two seasons (2009-10, 2010-11) and then signed a two year deal worth

$1,325,000 per season keeping him under contract until this current off-season.11

iv) The overall contribution to his club in the preceding season

Gunnarsson was definitely a contributing player to the Maple Leafs success last season.

He played significant minutes, averaging 21:17 per game.12 His offensive contribution was notable yet nowhere near the 29 and 28 points posted by Cody Franson and Dion

Phaneuf.13 Gunnarsson, however, had an on-ice corsi rating of -14.21.14 This means that over 60 minutes of 5 on 5 play, the Leafs averaged 14.21 less shots on net than the opposing team while Gunnarsson was on the ice. Of Leafs defenceman who played at least 12 games last season, Gunnarsson finished 6 out of 9 in terms of on-ice corsi.15 In fairness, Gunnarson was facing the third toughest opposition in terms of on-ice corsi of all Leafs defenceman.16 In the playoffs, however, Gunnarsson had the worst on-ice corsi of all leafs defenceman: -34.21 while facing only the third toughest opposition in terms of on-ice corsi amongst Leafs defenceman.17 Gunnarsson was also a -7 in the playoffs and only added one assist.18 Although 7 playoff games are less representative than a full season of play, considering Gunnarsson only played 37 regular season games last season, his playoff performance factors more strongly in assessing his overall contribution to the club’s success or failure last year. As such the Club takes the view that while Gunnarsson contributed to the Leafs success last year, his on ice corsi rating in the regular season and

11 http://capgeek.com/player/1212 12 Supra note 1. 13 http://mapleleafs.nhl.com/club/stats.htm 14 http://www.behindthenet.ca/nhl_statistics 15 Ibid. 16 Ibid. 17 Ibid. 18 Supra note 1. 5 his suspect performance in the playoffs raise legitimate concerns. As the saying goes: “Its not how you start, its how you finish”.

III. Player Comparison: Gunnarsson compared to Quincey and Stralman a) Criteria for Selecting Comparable Players

Aside from imposing the requirement that comparable players were eligible for salary arbitration either this off-season or last off-season, the following regular season statistics and factors were considered in selecting suitable comparable players to Carl Gunnarson: number of games played in the NHL, number of seasons played in the NHL (at least 10 to qualify), age (as of September 15 during salary arbitration eligible off-season), weight, height, regular season points per game, and regular season average time on ice. Each of these criteria were considered as of the off-season in which the player was eligible for arbitration. A comprehensive search yielded two relatively comparable players to Carl

Gunnarson: Kyle Quincey and Anton Stralman.

Player GP Seasons Age Weight Height PPG ATOI Gunnarsson 224 4 26 196 lbs. 6-2 0.31 20:32 Quincey 257 4 27 207lbs. 6-2 0.35 21:18 Stralman 265 5 26 193 lbs. 5-11 0.35 17.32 19 b) Gunnarsson vs Quincey: Why Gunnarsson does not quite match up

In the 2011-12 off-season (last year’s off-season) Kyle Quincey elected to go to salary arbitration but was able to settle with the for a two year deal worth

$3,775,000 a year.20 Below are Quincey’s statistics during the four seasons prior to his arbitration eligible year (the previous three seasons Quincey only played 13 NHL games):

19 http://www.hockey-reference.com/players/q/quincky01.html; http://www.hockey- reference.com/players/s/stralan01.html; http://www.hockey-reference.com/players/s/stralan01.html 20 capgeek.com/player/1008 6

Season Age Tm Lg GP G A PTS GC +/- PIM EV PP SH GW EV SH PP S S% TOI ATOI

2008-09 23 LAK NHL 72 4 34 38 11 -5 63 2 2 0 2 8 1 25 150 2.7 1511 20:59

2009-10 24 COL NHL 79 6 23 29 9 9 76 5 1 0 0 12 1 10 139 4.3 1865 23:37

2010-11 25 COL NHL 21 0 1 1 0 -5 18 0 0 0 0 1 0 0 39 0.0 411 19:35

2011-12 26 TOT NHL 72 7 19 26 9 -1 89 3 4 0 1 11 2 6 168 4.2 1574 21:52 21 In terms of +/- Quincey comes out as a -2 in the four seasons prior to his arbitration eligible off-season. However, if we discount Quincey’s 2010-11 season where he suffered a shoulder injury which forced him to miss the last 53 games of the season, he ends up a +3.22 Moreover, Quincey has played three relatively full NHL seasons (at least

72 games) and posted impressive offensive statistics in those years (38, 29, and 26 points respectively). In 2009-10 Quincey was +9 and added 6 goals and 23 assists with the

Colorado Avalanche. Overall the Avalanche were +11 that season, making Quincey’s +9 all the more impressive.23 In each of the three seasons in which Quincey was healthy he averaged over 20 minutes of ice-time establishing himself as a bona fide top-four defenceman who can contribute both defensively and offensively.

Gunnarsson on the other hand was a -2 and -9 in what will be referred to as his “two full

NHL seasons” (2010-11, 2011-12). Although Gunnarsson was a +5 in his platform year, the sample size is relatively small (only 37 games). Moreover, if we add the playoffs into the picture, Gunnarson actually drops to a -2 on the year. During Gunnarson’s two full seasons, he only averaged over 20 minutes of ice time in 2011-12 while averaging 18:15 minutes in 2010-11; numbers more indicative of a third pairing defenceman. Moreover, in Gunnarson’s two full NHL seasons he averaged only 0.29 and 0.25 points per game as opposed to Quincey’s tallies of 0.53, 0.37, and 0.36 in his three full years of NHL

21 http://www.hockey-reference.com/players/q/quincky01.html 22 http://www.tsn.ca/nhl/teams/players/bio/?id=3471 23 http://www.nhl.com/ice/standings.htm?season=20112012&type=DIV 7 hockey.24 Accordingly, the Club takes the position that in his year of eligibility, Quincey was a bona fide top four defenceman where Gunnarsson has yet to establish himself as such. c) Gunnarsson v Stralman: A Better Match

In the 2012 off-season Anton Stralman was eligible for salary arbitration but settled with the and signed a two year deal worth $1,700,00 a year. Below are

Stralman’s regular season statistics in the five seasons prior to his eligibility for salary arbitration:

Season Age Tm Lg GP G A PTS GC +/- PIM EV PP SH GW EV SH PP S S% TOI ATOI

2007-08 21 TOR NHL 50 3 6 9 3 -10 18 3 0 0 0 4 0 2 40 7.5 641 12:49

2008-09 22 TOR NHL 38 1 12 13 4 -2 20 1 0 0 1 7 0 5 43 2.3 592 15:34

2009-10 23 CBJ NHL 73 6 28 34 11 -17 37 2 4 0 0 10 0 18 121 5.0 1496 20:29

2010-11 24 CBJ NHL 51 1 17 18 5 -11 22 0 1 0 1 8 0 9 80 1.3 1006 19:44

2011-12 25 NYR NHL 53 2 16 18 5 9 20 2 0 0 0 12 0 4 55 3.6 906 17:06 25 The analysis here looks at Stralman’s three seasons prior to his eligibility for arbitration given that in 2007-08 and 2008-09 he was a relatively young player and received little ice time. Although Stralman was a -17 and -11 in his two seasons with the Columbus Blue

Jackets (2009-10, 2010-11) the Jackets were a dismal -43 as a team in both of those years, putting Stralman’s +/- into perspective.26 In his platform year, Stralman was a +9 on a comparatively much stronger New York Rangers squad. Although Stralman has really only played one full season of NHL hockey (2009-10), that season he demonstrated that he can contribute offensively by posting 34 points in 73 games for an average of 0.47 points per game while averaging over 20 minutes of ice-time. In the following two seasons Stralman posted points per game averages of 0.35, and 0.34, significantly better

24 Supra note 21. 25 http://www.hockey-reference.com/players/s/stralan01.html 26 Supra note 23 8 tallies than Gunnarsson (aside from Gunnarson’s very short platform year). Compared to

Gunnarsson then, Stralman is a more proven efficient offensive producer. Gunnarsson however played minutes consistent with a role as a top four defenceman in his platform year while Stralman’s minutes in his platform year are more consistent with a third pairing defenceman. Nonetheless, in his two years with the Jackets, Stralman proved he could handle top four minutes by averaging over 20 minutes a game. The upshot then is that Gunnarson was showing himself to be capable of a top four role in his platform year while Stralman’s status as a top four defenceman in his year of eligibility was more dubious. Gunnarssson therefore comes into his year of eligibility with more value than did Stralman, but not by much. The Club accordingly takes the position that both

Gunnarson and Stralman, as of their year of eligibility, had yet to truly establish themselves as bona fide and proven top four defenceman in the NHL in the way that Kyle

Quincey had. Thus the Club takes the view that Gunnarson’s compensation should be closer Stralman’s than to Quincey’s.

IV. Conclusion

In conclusion the Club respectfully takes the position that any award of salary for Mr.

Gunnarsson should be closer to the per annum value of Anton Stralman’s settlement for a two-year deal worth $1,700,000 as opposed to Kyle Quincey’s two year deal worth

$3,750,000 per annum. The mid-point between Quincey’s annual salary and Stralman’s annual salary is $2,737,500 per year. The Club therefore respectfully submits that any award to Mr. Gunnarsson should be worth $2,737,500 per year or less.