[JoeRedskin]

Here's the crux of it:

The Clubs’ contentions that the Reallocation Letter violates Article 12, Section 6(c)(v) of the CBA (which prescribes the method for determining the Salary Cap), Article 13, Section 1 (which provides that the “Salary Cap is the same amount for each Club”), Article 14, Section 2 (which proscribes agreements and other transactions that include terms designed to defeat or circumvent the parties’ intent as reflected by the CBA), and Article 17, Section 1 (which proscribes collusion to restrict or limit individual Club decisionmaking concerning designated matters) all must fail as a matter of law if the Reallocation Letter, as originally executed or as ratified by the March 27 Resolution, constitutes a valid amendment of the CBA.

http://media.washtimes.com/media/mis...llocations.pdf at page 3.