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IN THE MATTER OF A SALARY ARBITRATION

BETWEEN:

CODY FRANSON

-AND-

TORONTO MAPLE LEAFS

BEFORE: NATIONAL ACADEMY OF ARBITRATORS’

BRIEF IN SUPPORT OF A COMPENSATION REQUEST FOR THE CLUB

Team 32, In-house Counsel Hockey Club

Table of Contents

I. INTRODUCTION ……………………………………………………………3 II. THE PLAYER ………………………………………………………………..3 a. Defensive Liability ……………………………………………………….5 III. COMPARABLE PLAYERS …………………………………………………6 a. Jason Demers- …………………………………………...6 b. Nick Leddy-………………………………………...8 IV. CONCLUSION………………………………………………………………10

2 I. Introduction

This brief was prepared in support of the Toronto Maple Leafs in their arbitration hearing with Mr. . His election of salary arbitration is pursuant to Article

12.1 of the Collective Bargaining Agreement (CBA).

The Toronto Maple Leafs respectfully submits that Mr. Franson is entitled to an arbitration award in the amount of $3,000,000 over one year based on an evaluation of his performance, his platform season, and comparable players and their contracts.

II. The Player

Table 1: Cody Franson Regular Season Statistics1

GP G A P +/- PIM PPG SHG GWG S TOI/game 2009- 61 6 15 21 15 16 1 0 3 90 14:11 2010 2010- 80 8 21 29 10 30 2 0 2 156 15:10 2011 2011- 57 5 15 21 -1 22 2 0 0 65 16:11 2012 2012- 45 4 25 29 4 8 3 0 0 70 18:47 2013 2013- 79 5 28 33 -20 30 1 0 0 115 20:41 2014 NHL 322 28 105 133 8 106 9 0 5 496 ------totals *Bold year indicates his platform season

In 2013, Cody Franson signed a one-year contract with the Toronto Maple Leafs worth $2 million per year. He is a 27-year-old defenseman with the team with five years of professional experience and in three of those seasons, his team made the . He has played in 322 NHL games, scoring 133 points, and has a per game (PPG) career statistic of 0.41. In his platform year, Mr. Franson played 79 games, scoring 33 points (5 goals and 28 assists). He had a PPG statistic of 0.42. He spent 20: 41 on the ice on

1http://www.nhl.com/ice/player.htm?id=8471742

3 average per game, which is 3rd amongst Toronto Maple Leafs defensemen, behind Dion

Phaneuf and . Mr. Franson played over 20 minutes 47 times in his platform season and the Leafs only won 21 of those games, which is about 45% of their total games. He has an even strength TOI of 16:08, spending roughly 2:54 on the power play and 1:38 on the kill. Despite all that time on special teams, Mr. Franson scored 0 points on the penalty kill and only one on the power play.

During his platform season, Mr. Franson played primarily with Jake Gardiner and

Mark Fraser. Of the 1,686:06 minutes played, 607 minutes were with Jake Gardiner and another 225 were with Morgan Reilly.2 The remainder of that time was played with Mr.

Fraser before he was traded. Despite playing a large amount of time with Mr. Franson,

Mr. Fraser was a -8, Mr. Gardiner was only a -3, and Mr. Reilly was a -13. Mr. Reilly is also a rookie who improved as the season progressed.

It is clear that Cody Franson excels in the first half of the NHL season or when he has significant breaks. His best year in terms of points scored was 2012-2013, where he only played 45 games in a shortened NHL season and had a points per game statistic of

0.64, which is much higher then his career average of 0.41. In his platform year, Mr.

Franson scored 26 of his 33 points by the end of January, and 9 of those points came in

October3. Mr. Franson had a significant break after that month because of the Sochi

Winter Olympics. When the season’s games were squeezed together after the Olympics,

Mr. Franson had trouble scoring consistently. He was tied for 102nd in the NHL in point

2 http://blogs.edmontonjournal.com/2014/07/21/cody-franson-of-the-toronto-maples-leafs-is-on-the-block- should-the-edmonton-oilers-be-interested/ 3http://www.nhl.com/ice/player.htm?id=8471742&docid=TeamPlayerBio:43094#&navid=nhl-search

4 scoring rate at even strength, and the year before was ranked 2nd. 4 This lack of consistency in scoring is a big problem like a team for the Leafs, who frequently spend the last month and a half of their season fighting for a playoff spot. In his platform season, the team was 10 points out of a playoff spot, losing 14 games by one goal (28 points lost)5. This lack of team scoring is not attributable to Mr. Franson alone, but as one of the top 4 defensemen on the team, he should be stepping up in the second half of the season and scoring as consistently as he does in the first half.

A. Defensive Liability

Mr. Franson is one of the top 4 defenseman on the Toronto Maple Leafs, yet in his platform year it became clear that he is becoming a defensive liability. In his platform year, Mr. Franson has a plus minus rating of -206. This is ranked 857th in the NHL7. As a result of his poor defensive player, Mr. Franson played against lesser. The only defenseman with at least 79 starts with a worse plus minus then Cody Franson are Keith

Yandle (who still scored 53 points and played 24:08 a game on a poor defensive team),

Seth Jones (who was a rookie), Milan Michelek and Christian Ehrhoff (who played on the worst team in the NHL)8. When playing for the Predators, Mr. Franson did have a positive plus minus statistic, however he played much less minutes (going from 14:12 on the ice in 2009 to 20:429 a game on the ice in his platform year). Mr. Franson’s overall plus minus in two years with the Leafs is a -1710. Additionally, he ranked 22nd in the

4 http://blogs.edmontonjournal.com/2014/07/21/cody-franson-of-the-toronto-maples-leafs-is-on-the-block- should-the-edmonton-oilers-be-interested/ 5 http://mapleleafs.nhl.com/club/app 6 http://www.nhl.com/ice/player.htm?id=8471742 7 IBID 8 http://www.nhl.com/ice/playerstats.htm 9 http://www.hockey-reference.com/players/f/fransco01.html 10 http://www.hockey-reference.com/players/f/fransco01.html

5 NHL in giveaways (79) in his platform season, which amounts to 2.5 giveaways per 60 minutes played. 11

III. Comparable Players

A. Jason Demers12

Table 2: Jason Demers Regular Season Statistics GP G A P +/- PIM PPG SHG GWG S TOI/game 2009- 51 4 17 21 5 21 3 0 1 52 15:25 2010 2010- 75 2 22 24 19 28 0 0 0 105 19:29 2011 2011- 57 4 9 13 -8 22 2 0 1 73 16:50 2012 2012- 22 1 2 3 -4 10 0 0 0 27 18:37 2013 2013- 75 5 29 34 14 30 1 0 0 105 19:29 2014 NHL 280 16 79 95 26 111 6 0 2 362 ------totals *Bold year indicates his platform season

In 2014, Jason Demers signed a two-year contract with the San Jose Sharks worth

$3.4 million per year. Mr. Demers is a 26-year-old defensemen for the San Jose Sharks.

He has five years of professional hockey experience and playoff experience. He has played in 280 NHL games, scoring 95 points, and has a PPG career statistic of 0.34, which is close to Mr. Franson’s 0.41. In his platform year, Mr. Demers played 75 games, scoring 34 points (5 goals and 29 assists), which is nearly identical to Mr. Franson’s 33 points. Mr. Demers has extensive playoff experience (39 games), playing in at least 1 game for every season he has played in the NHL. While Mr. Franson has 23 games of

11 http://www.sportingcharts.com/nhl/stats/player-giveaways-statistic/2013/ 12http://www.nhl.com/ice/player.htm?id=8474218&docid=TeamPlayerBio:36333#&navid=nhl-search

6 playoff experience, most of that came in two seasons with the . Mr.

Demers has an identical even strength TOI to Mr. Franson (16:08) in his platform season.

Mr. Demers had an excellent plus minus in his platform season with the Sharks.

He had a +14, which is a 34 point differential to Mr. Franson. An argument can be made here that Mr. Demers played on a strong defensive Sharks team but he is a big part of the team’s success and consistent playoff appearance. His 34 points is a career high and he was ranked 2nd on the Sharks behind Dan Boyle in 2013. Following Mr. Boyle’s departure from the team, Mr. Demers will be relied on as one of the top defensemen on the Sharks and was compensated as such in his new contract. Mr. Demers has proved through his consistent and improving play that he is capable of logging top pairing minutes, and has done particularly well on the penalty kill for the Sharks.

Mr. Demers is also only improving in his play on the ice, whereas Mr. Franson has reached a plateau. He is already one of the more relied upon defensemen for the

Leafs, whereas Mr. Demers is on his way to becoming one of the top 2 defensemen for the Sharks. In his first NHL season, he played 15:25 per game, whereas in his fifth season, he played 19:29 per game. Mr. Demers is only gaining more responsibility whereas Mr. Franson is consistent and probably won’t gain much more ice time.

Points wise, Mr. Demers has scored more consistently throughout the season

(October-April) of his platform year then Mr. Franson has. 10 of his 34 points actually came in the last two and half months of the season.

Mr. Demers is slowly developing into one of the top 2 defensemen on the San

Jose Sharks, has extensive playoff experience, scores more consistently throughout the season, is defensively much more responsible then Mr. Franson and is a year younger

7 then he is. For those reasons, the Maple Leafs believe that Mr. Franson deserves below the $3.4 million per year that Mr. Demers is earning with the San Jose Sharks.

B. Nick Leddy13

Table 3: Nick Leddy Regular Statistics

GP G A P +/- PIM PPG SHG GWG S TOI/game 2010- 46 4 3 7 -3 4 0 0 0 37 14:18 2011 2011- 82 3 34 37 -12 10 0 0 0 94 22:04 2012 2012- 48 6 12 18 15 10 2 0 2 65 17:25 2013 NHL 176 13 49 62 0 24 2 0 2 196 ------totals

In 2013, Nick Leddy signed a two-year contract with the Chicago Blackhawks worth $2.7 million per year.14 At the time, he had three years of professional hockey experience, and three years of playoff experience. Prior to his new contract, Mr. Leddy played in 176 games, scoring 62 points, and at the time, had a PPG career statistic of

0.35, which is slightly lower then Mr. Franson’s 0.41. In his platform year in 2012-2013,

Mr. Leddy played 48 games, scoring 18 points. In the same shortened season, Mr.

Franson played more games and scored 29 points. Mr. Leddy also has extensive playoff experience (36 games), playing at least 6 games in every year he has been in the NHL.

Mr. Leddy was also a key member of the Champion Blackhawks in his platform season, scoring 2 points. The Chicago Blackhawks also won the President’s

Trophy that year.

13http://www.nhl.com/ice/player.htm?id=8475181&docid=TeamPlayerBio:47924#&navid=nhl-search 14 http://www.capgeek.com/player/1830

8 Mr. Leddy had an excellent plus minus in his platform season. He had a +17, which is a 37 point differential to Mr. Franson. An argument can be made that Mr. Leddy played on an incredibly strong defensive team. Two of Blackhawks’ best defensemen,

Duncan Keith and , were Olympic Champions in 2010 and have won two

Stanley Cups with the team each. Despite that, in his platform season Mr. Leddy still found a way to contribute, with 17:25 of ice time per game in the regular season and

14:20 per game in the playoffs as a 22 year old. He also only had 18 giveaways in his platform season, which averages out to 1.29 giveaways per game. That number tied Mr.

Leddy for 241st in the NHL in 2012-2013. 15

Mr. Leddy is young and is only getting better. As mentioned before, Mr. Franson has reached a plateau of sorts. Mr. Leddy is on his way to becoming one of the top four defensemen on the Chicago Blackhawks and one of the most relied upon on the team. In his first NHL season, he played 14:18 and in his platform season jumped to 17:25. That time on the ice is only improving as Mr. Leddy gets older and stronger. Mr. Leddy happens to be one of the best skaters on the Blackhawks with incredibly mobility and acceleration. He has great vision and passing skills, which is evident by the fact that in his platform year, he scored double the assists that he did goals.

Points wise, Mr. Leddy has scored much more consistently throughout the season

(January-April) of his platform year then Mr. Franson did. He scored at least three points every month, and had his best month in March, when the Blackhawks were making a push to the playoffs. Mr. Leddy is consistent through the season, and is at his best in the middle, when his team will be working hard to qualify for the postseason.

15 http://www.sportingcharts.com/nhl/stats/player-giveaways-statistic/2012/

9 It is clear that Mr. Leddy is a young, improving defensemen that has incredible potential. Despite the fact that he is 4 years younger then Mr. Franson, he has played in

13 more playoff games then Mr. Franson, and has a Stanley Cup to show for that. He is slowly developing into one of the most relied upon second pairing defensemen on his team. Mr. Leddy has extensive playoff experience, has won a Stanley Cup, is more defensively responsible then Mr. Franson, is younger then him, and scores more consistently throughout the season. However, Mr. Franson has 2 more years of NHL experience then Mr. Leddy and is more physically developed. For that reason, the Maple

Leafs believe Mr. Franson deserves slightly above the $2.7 million per year that Mr.

Leddy is earning with the Chicago Blackhawks.

IV. Conclusion

Based on an evaluation of Mr. Franson’s career statistics, his platform season, his overall contribution to his club, the club respectfully submits that the arbitrator award him a one year contract in the amount of $3,000,000. Mr. Demers, who earns $3,400,000 with the San Jose Sharks, has more playoff experience, is quickly becoming one of the top defensemen on a talented Sharks team. Mr. Leddy, who earns $2,700,000, is younger then Mr. Franson, is a Stanley Cup winner, is a much more consistent scorer, and is defensively responsible. For those reasons, the Toronto Maple Leafs believe Mr. Franson is entitled to $3,000,000 over one year.

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