Because his whole last type of holdout bullet point is about Tom Brady's contract situation, and how he thinks it will play out.
Now imagine you're Tom Brady. You left money on the table that your team rarely used (only splurging in 2007). You watched them repeatedly roll over high picks so "next year" would be the windfall instead of just cashing them in during your prime. Now you're 33 years old with a surgically repaired knee. You're playing for a paltry $6.5 million during an uncapped season -- repeat: an uncapped season -- during the same year that rookie Sam Bradford just signed for $50 million guaranteed. You thought for sure the Patriots would renegotiate that deal when the time came, and they even promised as much -- the old, "We need to stretch the signing bonus out for cap purposes and add an extra year, but don't worry, when we get there, we'll rip it up" routine -- only they're now pretending to have amnesia. And by the way, you won three Super Bowls and helped sell out their stadium for nine solid years.
What does he think Tom will do? You can read the end of the article. But it also contains the usual Simmons fun, with rips on everyone from Favre to LeBron.