Balsillie finally applies to NHL for relocation

Jim Balsillie has filed an application with the National Hockey League for the relocation of the Phoenix Coyotes, including details of what he's planning if the league lets him move the team to Ontario.

The move had been expected for some time but, contrary to published reports, the formal application was not made until late Monday night.

Balsillie, the billionaire co-CEO of BlackBerry maker Research In Motion Ltd., has offered to buy the Coyotes out of Chapter 11 bankruptcy for $212.5 million US on the condition that he be allowed to move the team to southern Ontario — specifically, Hamilton.

The NHL is challenging the proposed sale in an Arizona bankruptcy court, claiming that Coyotes owner Jerry Moyes gave up the right to sell the club by signing a proxy last November. The NHL also claims it controls any potential relocation through its constitution and the needed approval of its board of governors.

Monday's relocation application, written for Balsillie by former Canadian Football League commissioner Tom Wright, includes details of why the league should consider Balsillie's proposal.

The plan includes a $150-million renovation of Hamilton's 24-year-old Copps Coliseum that Balsillie told The Canadian Press news agency will make the building perhaps the "most advanced and modern and complete facility in the NHL."

Complying with rules

"We put together all of the elements of the design, the market and updating the facility and stuff like that," Balsillie said. "It's an important and comprehensive document....

"Really, this is all about ... just complying with the league rules and regulations."

Balsillie's relocation application is one of several documents to be submitted this week.

Lawyers for the NHL and Moyes have been given a Friday deadline by bankruptcy Judge Redfield T. Baum to present written arguments in his court about whether the team can be moved as part of a sale.

Baum will preside over a June 9 hearing where the parties will make their respective cases verbally and has said he intends to make a prompt ruling on the relocation issue.

Depending on what is decided at the hearing or shortly after, an auction to sell the Coyotes could be held as early as June 22.

On Monday, the NHL filed a motion with the bankruptcy court, arguing that information regarding previous relocations of its clubs is not legally relevant to the Coyotes' case.

Representatives of Moyes are requesting documents about NHL relocations to Carolina, Colorado, Dallas and Phoenix itself, whose team moved from Winnipeg in 1996.

The request came after the NHL asserted at a court hearing last week that the Coyotes couldn't be moved for next season, due to the 2009-10 game schedule being basically completed, among other reasons.

Lawyers for Moyes have also requested all documents from the NHL from Balsillie's previous attempts to buy the Pittsburgh Penguins and the Nashville Predators, as well as any proposed amendments to Section 4.3 of the NHL constitution, which relates to territorial rights of league members.

The NHL said in its motion Monday that until the relocation issue is dealt with by the court, those two areas are not relevant.

The league also argued it wasn't necessary to produce the documents because Balsillie had yet to file a request for relocation, but that contention became moot when the relocation application was filed Monday night.