NHL 2K10

A short-handed goal is scored when one team has one (or two) fewer players on the ice since they committed a penalty.

Simply turn penalties all the way up and check (hit) the opposing team's goalie. This should draw a penalty very quickly. Once the penalty has been called, you can turn all the penalties off.

With one (or more) of your players in the penalty box, score a goal. Repeat three times.

just get a total of 3 short handed goals over your playing career i got this in the first game i played because of the many penalties i got in the game.