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Jim Balsillie files relocation application with NHL for the Phoenix Coyotes

Jim Balsillie co-CEO of RIM (Research In Motion) speaks to the media, May 25, 2009. THE CANADIAN PRESS/Dave Chidley

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Jim Balsillie co-CEO of RIM (Research In Motion) speaks to the media, May 25, 2009. THE CANADIAN PRESS/Dave Chidley

The NHL now has a clearer picture of what Jim Balsillie has planned if the Phoenix Coyotes are allowed to move to Hamilton.

A spokesman for Balsillie said the application for the team's relocation was filed with the league office in New York late Monday. It includes intricate details about why he believes the NHL should consider his proposal to purchase the NHL team for US$212.5 million and bring it to southern Ontario.

"We put together all of the elements of the design, the market and updating the facility and stuff like that," Balsillie said in an interview with The Canadian Press earlier Monday. "It's an important and comprehensive document. ...

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

Former CFL commissioner Tom Wright prepared the relocation document for Balsillie.

Deputy commissioner Bill Daly declined to comment when contacted by email.

Balsillie, the co-CEO of RIM, is seeking to purchase the Coyotes out of Chapter 11 bankruptcy and move the team to Copps Coliseum as soon as next season. A key part of his plan is a $150-million renovation to the 24-year-old building that Balsillie believes will make it arguably the "most advanced and modern and complete facility in the NHL."

The league contends that its bylaws allow it to make final decisions on relocation and that Coyotes majority owner Jerry Moyes has no right to sell the team conditional on a move to southern Ontario because he has no control over that territory.

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

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

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

His decision will dictate whether Balsillie can become an NHL owner after years of trying. The Canadian billionaire is looking forward to seeing what happens.

"This is about facts and rules and law," said Balsillie. "He's fundamentally respecting the fact that creditors matter. We expect that he'll also respect the fact that we're not looking to upend anything in the NHL. We're fully committed to being a good owner and a respective member of the board of governors. ...

"We're excited that the judge is obviously - as he should - taking the creditors' interests very seriously. He sees us as a very strong and bona fide offer."

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