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Home , Defenceman, James van Riemsdyk, Morgan Rielly, Official (ice hockey), Phil Kessel, Randy Carlyle

IN THE MATTER OF SALARY ARBITRATION BETWEEN:

CODY FRANSON

- AND -

THE MAPLE LEAFS HOCKEY CLUB

BRIEF IN SUPPORT OF CODY FRANSON

(TEAM 8)

I. INTRODUCTION AND OVERVIEW ...... 3

A. Physical Offensive ...... 3

B. Sustained Progression of Defensive Abilities ...... 5

C. Contribution to the Hockey Club ...... 6

II. VALID COMPARABLE PLAYERS ...... 7

A. Kyle Quincey (Age: 29, HT: 6’2”, WT: 216 lbs.) - ...... 7

B. Jason Demers (Age: 26, HT: 6’1”, WT: 195 lbs.) – ...... 9

III. CONCLUSION………………………………..……………………………………………10

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I. INTRODUCTION AND OVERVIEW: This brief is in support of defenceman Cody

Franson’s (“Mr. Franson”) position in salary arbitration with the Toronto Maple Leafs Hockey

Club (the “Leafs” or the “Club”). Mr. Franson is in his final off-season as a Group 2 Restricted

Free Agent (“RFA”) as he will be 27 years old before June 30, 2015. Mr. Franson’s permissible

election for salary arbitration pursuant to Article 12.9(c)1 will only allow the awarding of a one-

year contract. In accordance with Article 12.9(g)2 of the CBA, in determining a salary arbitration

award value, an evaluation of Mr. Franson’s career statistics and overall contribution to the Club

will be conducted. Mr. Franson will also be evaluated in comparison to NHLPA edible players.

Based upon these evaluations, Mr. Franson respectfully submits that an award above the $3.3

million midpoint figure is a reasonably fitting award, and that a one-year contract for $3.65

million is justified.

A. Physical Offensive Defenceman

At 6’5” and 215 lbs., Cody Franson is a physically imposing defenceman who

demonstrates great offensive instincts. He has spent his NHL career with the

and the Leafs. Mr. Franson, the 79th overall selection in 2005, was traded to the Leafs in a 2011

multi-player deal.3 Since then, Mr. Franson has played three seasons with the Leafs as a physical

offensive defenceman who has become a staple on the Leafs’ 5th ranked, ’14-’15, power play.4

Table 1: Cody Franson’s NHL Career Statistics5 Season GP G A PTS +/- PPG PP PIM SOG TOI/g HITS BkS GvA TkA A (NSH) 2009-2010 61 6 15 21 15 1 5 16 90 14:11 55 53 22 19 (NSH) 2010-2011 80 8 21 29 10 2 4 30 156 15:10 81 52 39 29 (TOR) 2011-2012 57 5 16 21 -1 2 5 22 65 16:11 102 53 45 20 (TOR) 2012-2013 45 4 25 29 4 3 10 8 70 18:47 124 59 40 21 (TOR) 2013-2014 79 5 28 33 -20 1 17 30 115 20:41 282 111 68 50

1 NHL Collective Bargaining Agreement, 2012, s.12. 2 Ibid. 3 http://www.tsn.ca/nhl/player-bio/cody-franson/bio 4nhl.com/ice/teamstats.htm?fetchKey=20142ALLSAAALL&sort=powerPlayPercentage&viewName=powerPlay 5 www..com/ice/playerstats

3 Career 322 28 105 133 8 9 9 106 496 - 644 328 214 139

Mr. Franson’s statistics immediately indicate a player that delivers a substantial amount

of body checks, averaging two hits per game over his career. Mr. Franson’s prowess for physical

play established him as league leader for hits amongst NHL defencemen last season—averaging

3.6 hits per game.6 Mr. Franson is not just an impressive hitter, he is the league’s best; for a

second straight year he lead all top 40 NHLers in hits per minute, incurring only one

penalty minute for every 9.4 hits last season and one penalty minute for every 15.5 hits the year

before.7 This finding demonstrates Mr. Franson’s ability to utilize his large frame to frequently

deliver clean and punishing bodychecks against his opponents.8 Although he is aggressive, his

discipline proves especially important to the Maple Leafs last season as it saved the team from

having to endure the NHL’s third worst penalty kill (78.4 PK%)9.

In spite of his highly physical playing style, Mr. Franson’s body has suffered minimally,

missing a total of 13 games to injury in the past five seasons.10 His capacity to endure physical

NHL play cannot be understated, as it allows the Leafs to be consistently protected by their

prolific defenceman game after game.

Another area where Mr. Franson is preeminent is in his ability to register shots on ;

this especially important asset has solidified him as a main fixture on one of the NHL’s elite

power-play units. Mr. Franson’s accurate, quick-release and blistering are ideal for finding

a way to get puck through traffic and on net. His puck moving and shooting ability generated 18

power play points (1 PPG, 17 PPA), and 33 points in total (5 G, 28 A) last season. His offensive

6 Using NHL statistics for 2013-14, hits (“HITS”) were divided by games played (“GP”) to reach this ratio. 7 Using official NHL statistics, hits (“HITS”) were divided by penalty minutes (“PIM”) to reach this ratio. 8 www.nhl.com/ice/playerstats 9 www.nhl.com/ice/teamstats 10 http://www.tsn.ca/nhl/player-bio/cody-franson/bio

4 output established him as the Maple Leafs top scoring defenceman and tied him for second in power play points behind (20 PPP).11

Accordingly, due to his exceptional prowess for clean and punishing physical play, ability to remain healthy, and substantial offensive impact, Mr. Franson submits that he is entitled to an arbitration award exceeding the $3.3 million midpoint figure.

B. Sustained Progression of Defensive Abilities

Although Mr. Franson exhibits great offensive instincts, his value as an NHL defenceman must also be founded upon his defensive capabilities. Looking at Mr. Franson’s past five NHL seasons, it can be readily seen that he has demonstrated a sustained progression of his defensive abilities. In analyzing improvements under categories such as: i.) Takeaways (TkA); ii.) Blocked

Shots (BkS); and iii.) Average Time on Ice per Game (TOI/g), it becomes clearer that Mr.

Franson continues to develop into a trustworthy asset with great defensive aptitude. Ranking 5th among NHL defenceman last year for his 50 takeaways12, Mr. Franson’s continuing development indicates strong positional play that breaks up oppositional plays.

Although Mr. Franson’s giveaways outnumber his takeaways, this is more indicative of high pressure play often moving through Mr. Franson rather than a display of poor puck possession. To be explained simply, those who frequently give away the puck, also frequently have the puck in their possession. For example, 2013-14 Norris Trophy winner yielded 70 giveaways to his 48 takeaways that same year.13

Mr. Franson’s contribution in blocking has dramatically increased over the past two seasons. Mr. Franson blocked 170 shots in 124 in his past two seasons (1.37 BkS/game)14; this is a substantial improvement over his first three NHL seasons where 158 shots were blocked in 198

11 www.nhl.com/ice/playerstats 12 http://www.sportingcharts.com/nhl/stats/player-takeaway-statistics/2013/ 13 www.nhl.com/ice/playerstats 14 Using official NHL statistics, blocks (“BkS”) were divided by games played (“GP”) to reach this ratio.

5 games (0.80 BkS/game)15. The improvements to his blocked shot numbers directly aligns with coach ’s only full seasons with the Leafs, suggesting Mr. Franson to be a professional who is able to adopt his game to coaching expectations16. With Franson’s big frame blocking the more direct paths to the net, it’s no wonder that the Leafs’ opponent’s shooting percentage suffered last year, from 9.47% to 8.09% when Franson was on the ice. Further to this point, Mr. Franson’s rising TOI/g over the past five seasons denotes progression of a trustworthy defenceman that is increasingly relied upon to play significant minutes. His continuing progression as a well-rounded NHL defenceman with size is of great value to the Leafs and consequently, should increase Mr. Franson’s award.

C. Contribution to the Toronto Maple Leafs Hockey Club

Aside from Mr. Franson leading the Club in points amongst defencemen for the past two seasons, being an essential element of one of the NHL’s most potent power plays, and playing significant minutes for the Club; Mr. Franson is also a remarkable playoff performer. On a team where a majority of the players have very little playoff experience, Mr. Franson’s 23 postseason games cannot be discounted. Although Mr. Franson put up very admirable playoff numbers in his rookie and sophomore seasons, his series against the eventual 2013 Finalists, the

Boston Bruins, was truly an exceptional performance.

Table 2: Cody Franson’s Playoff Statistics17 Season GP G A PTS +/- P/GP PPG PIM TOI/g HITS (NSH) 2009-10 4 0 1 1 1 0.25 0 2 9:02 4 (NSH) 2010-11 12 1 5 6 0 0.50 0 0 15:19 8 (TOR) 2012-13 7 3 3 6 0 0.86 1 0 22:49 33 Career 23 4 9 13 1 0.57 1 2 - 45

In seven games against the Eastern Conference powerhouse, Mr. Franson averaged 0.86 points per game (P/GP), doled out 33 hits without incurring any penalty minutes, and played the

15 Ibid. 16 http://www.thescore.com/nhl/news/581836 17 www.nhl.com/ice/playerstats

6 third most minutes for the Club. His three goals and three assists were good enough to place him third behind and Phil Kessel for Leafs playoff points leaders. This comes as no surprise, as Franson is precisely the type of Defencemen built for championship winning playoff hockey. Franson’s relentless and intense physicality will continue to establish him as invaluable especially in playoff hockey. The modern NHL’s champions have proven that this is what makes the difference between a top seed and a Stanley Cup Champion. His style of play is precisely conducive to playoff success. His uncanny ability to constantly but cleanly bruise the bodies of his opponents with heavy hits helps the team throughout a gruelling playoff series. He proves physically and mentally able to take a toll on his body while energizing his teammates and constantly punishing, intimidating and frustrating opponents. He takes opponents out of the play, often resulting in 5 on 4 situations because the opponents are out of the play or because it frustrates them into retaliating and taking a penalty. Franson embodies the intensity, levelheadedness, youth, durability and consistency relied on to be a champion. Considering his upward trending playoff contribution and stellar performance, Mr. Franson submits that his award be above the $3.3 million midpoint.

II. VALID COMPARABLE PLAYERS A. Kyle Quincey (Age: 29, HT: 6’2”, WT: 216 lbs.) - Detroit Red Wings In July of 2012, Group 2 RFA Kyle Quincey re-signed with Detroit for two years at an average annual salary of $3.775 million.18 Both these players are large framed NHL defencemen that move the puck well and are relied upon to log considerable ice time. In the season leading up to his re-signing, Mr. Quincey averaged 19:13 minutes of ice time per game, slightly besting Mr.

Franson’s 18:47 per game.19 Their plus-minus ratings were also similar, as Mr. Quincey posted a rating of plus 7 and Mr. Franson a plus 4. However, in that year, Mr. Franson outperformed Mr.

18 www.capgeek.com 19 www.nhl.com/ice/playerstats

7 Quincey in a number of categories. Mr. Franson generated 29 points, while Mr. Quincey posted only 3. Mr. Franson delivered 124 hits, while Mr. Quincey made only 29.20 Mr. Franson also stayed out of the penalty box more often as evidenced by his 8 PIMs to Mr. Quincey’s 18 PIMs.

Mr. Franson did not only meet and exceed Mr. Quincey’s statistics that year, but he has outperformed Mr. Quincey across their respective careers. Despite playing 53 less career games,

Mr. Franson has bested Mr. Quincey in almost every significant statistical category, accumulating more goals, assists, power play goals, game winning goals, hits, and two-thirds less penalty minutes.21 In spite of posting a glaring minus 20 last season; Mr. Franson still boasts a career plus 8 rating to Mr. Quincey’s career minus 3.22

Table 3: Regular Seasons Career Comparator23 Defenceman GP G A +/- PPG PPA GWG PIM HITS Quincey 375 23 88 -3 7 47 4 356 477 Franson 322 28 105 8 9 41 5 106 644

Beyond Mr. Franson’s better numbers, there exists crucial differences in both players’ injury history. Mr. Quincey, who has a history with concussions, has missed 42 games over his career due to injury.24 This is a stark contrast to Mr. Franson’s 13 missed games and lack of any concussion history. Due to similar the playing styles, physical characteristics, and ages of both players, as well as Mr. Franson’s superior statistics and ability to remain healthy, Mr. Franson submits that an award near the $3.775 million range is quite appropriate.

B. Jason Demers (Age: 26, HT: 6’1”, WT: 195 lbs.) – San Jose Sharks

In July of 2014, Group 2 RFA Jason Demers re-signed with San Jose for two years at an average annual salary of $3.4 million.25 Although Mr. Franson is four inches taller, both of these players are considered large framed NHL defencemen that can play a physical game and play

20 Ibid. 21 Ibid. 22 Ibid. 23 Ibid. 24 http://www.tsn.ca/nhl/player-bio/kyle-quincey/bio 25 www.capgeek.com

8 significant minutes. Both defencemen are also main fixtures on their respective power play units

because of their great passing and shooting ability.

Table 4: 2013-14 Regular Season Comparator26 Defenceman GP G A +/- PPG PPA BkS PIM HITS GvA TkA Demers 75 5 29 14 1 8 107 30 69 69 40 Franson 79 5 28 -20 1 17 111 30 282 68 50 Last season both players were relied upon significantly as Mr. Demers averaged 19:29

minutes of ice time per game, while Mr. Franson edged him out with 20:41.27 Looking at their

2013-14 numbers, it is quite apparent that both players put up similar performances in a number

of pertinent statistical categories. However, under some categories there are significant

differences. Mr. Demers was a plus 14 last year on a team with the 5th lowest goals against

average in the NHL last year; Mr. Franson on the other hand put up a career worst minus 20 on a

team who was third worst in the same category. Mr. Franson, being relied upon for his

leadership, was tasked to pair with defensively weak28 rookie and sophomore Jake

Gardiner for a substantial portion of the season. The Maple Leafs weak play overall and having to

play alongside such little NHL experience may explain why a career plus player like Franson had

a weak showing in this category. Looking at Franson’s previous years and his career plus 8.

However, in the same year, Mr. Franson accumulated ten more takeaways, doubled the amount of

power-play assists, and laid just over four times the amount of hits than Mr. Demers did.

Table 5: Regular Seasons Career Comparator29 Defenceman GP G A +/- PPG PPA BkS PIM HITS GvA TkA Demers 280 16 79 26 6 25 301 111 290 180 101 Franson 322 28 105 8 9 41 328 106 644 214 139 Looking at the respective career comparables, it is immediately evident that Mr. Franson

delivers considerably more hits. Mr. Franson is also more disciplined when it comes to penalty

26 www.nhl.com/ice/playerstats 27 Ibid. 28 http://stats.hockeyanalysis.com/showplayer.php?pid=1210 29 Ibid.

9 trouble, incurring less penalty minutes while playing 42 games more than Mr. Demers. Also, Mr.

Franson delivers a career average of 6.07 hits per penalty minute received, while Mr. Demers’ average is 2.61.30 This demonstrates that Mr. Franson embodies a playing style that is much more physical and disciplined. Additionally, Mr. Franson’s 0.41 points per game average is superior to

Mr. Demers’ 0.34.31 There is also a substantial difference in how well each of these players have performed in the playoffs. Mr. Demers playing 39 career playoff games with a perennial contender only managed 9 points for his team while posting a minus 6 rating and 32 penalty minutes.32 Conversely, in only 23 career playoff games, Mr. Franson has generated 13 points, is a plus 1, and has only incurred 2 penalty minutes. Additionally, Mr. Franson’s best playoff performance has come with a hockey club that has appeared only once in the playoffs within the last ten years. Considering many of the statistical similarities between the players, as well as Mr.

Franson’s outperformance of Mr. Demers in key regular season and playoff categories, Mr.

Franson submits that he is entitled to an award greater than Mr. Demers’ $3.4 million salary.

III. CONCLUSION:

Mr. Franson is an invaluable defenceman. His demonstrated offensive instincts, elite hitting ability, integral role on the power play, and substantial defensive development. In comparing Mr. Franson to similar players in the appropriate contract range, it is clear that he is entitled to an award surpassing the $3.3 million amount, and that a one-year contract of $3.65 million is a reasonable award.

30 Using official NHL.com statistics, hits (“HITS”) were divided by penalty minutes (“PIM”) to reach this ratio. 31 www.nhl.com/ice/playerstats 32 www.nhl.com/ice/playerstats

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