IN THE MATTER OF SALARY ARBITRATION BETWEEN: CODY FRANSON -AND- THE TORONTO MAPLE LEAFS SUBMISSION OF BEHALF OF THE TORONTO MAPLE LEAFS TEAM 28

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1 IN THE MATTER OF SALARY ARBITRATION BETWEEN: CODY FRANSON -AND- THE TORONTO MAPLE LEAFS SUBMISSION OF BEHALF OF THE TORONTO MAPLE LEAFS TEAM 28

2 TABLE OF CONTENTS TABLE OF CONTENTS... 2 I. INTRODUCTION AND OVERVIEW... 3 A. OVERALL PERFORMANCE IN CAREER... 3 B. OVERALL CONTRIBUTION TO TEAM SUCCESS... 5 II. VALID COMPARABLE PLAYERS... 6 A. TYSON BARRIE - COLORADO AVALANCHE - $2.6 MILLION SALARY... 6 B. NICK LEDDY - CHICAGO BLACKHAWKS -$2.7 MILLION SALARY... 7 C. ALEC MARTINEZ - LOS ANGELES KINGS- $1.1 MILLION SALARY... 8 III. CONCLUSION

3 I. INTRODUCTION AND OVERVIEW In accordance to article 12 of the NHL collective bargaining agreement, this brief will analyze the overall value of Cody Franson in support of a $2.3 million salary demand. Cody Franson s lack of overall contribution to the Toronto Maple Leafs, his inconsistent offensive production, and his lack of defensive reliability prevent him from being deserving of a salary arbitration award of more than the $3.3 million midpoint. Furthermore, the quality of defenseman that will be used as comparables that are currently making less than much less than $3.3 million midpoint far outweigh the overall current quality of Cody Franson as a reliable NHL defenseman. For the aforementioned reasons that will be discussed in the following brief, Cody Franson should be awarded a salary of $2.3 million per year. A. Overall Performance In Career SEASON TEAM GP G A P +/- PIM PPG SHG GWG S S% PREDATORS MILWAUKEE ADMIRALS-AHL PREDATORS MAPLE LEAFS MAPLE LEAFS BRYNAS IF GAVLE SWEDEN MAPLE LEAFS NHL TOTALS Cody Franson played almost a full season, playing 79 games, and recording 5 goals and 28 assists 1. Franson averaged 20:41 TOI per game, good for third 1 3

4 among defenseman behind Gardiner and Phaneuf 2. Franson s point production regressed substantially from the season, where he recorded a remarkable 29 points in 45 games (64 pts/game) 3. Franson recorded 21 points in 51 games during the season, and 29 points in 80 games during the season 4. Franson s overall scoring record during his past 4 NHL seasons has thus been somewhat inconsistent. By analyzing his point distribution, we can see that even Franson s point production during the season, let alone his career, have been consistently inconsistent. On 6 different occasions, Franson recorded a point in consecutive games, making up for 20 points out of the 29 points he recorded during the season, or 68% of his total points 5. Although this is an indication to the offensive potential that Franson has as a top-tier offensive NHL defenseman, it is also indicative of his inconsistency at this point in his career as he tends to produce points in bunches, not consistently over the course of a season. To further emphasize this point, Franson started the season scoring 26 points in 54 games, but ended the year with only 7 points in the last 25 games, including the crucial stretch of games during the post-season push 6. Furthermore, 24 points of his 29 points, or 83 % of his points, were recorded at home last season 7. This stat suggests inconsistent offensive play away from home, where Franson could more easily be intimated. Franson also has a low percentage 2 try=&status=&viewname=summary#

5 of 5 on 5 points, as only 39.3 % of his 28 assists during the season were scored at even strength 8. In this manner, Franson s streaky habit of scoring points in bunches, and his inconsistency of offensive production away from home and over the course of a season indicate that he not yet at the level of a top offensive NHL defenseman. Responsible play is the value Franson currently brings to the Leafs; it is utterly underwhelming and onedimensional. B. Overall Contribution to Team Success Cody Franson was a minus 20 last season, down from a plus 4 during the season. One of the main reasons for this is that Franson`s role expanded from a 3 rd pairing defenseman in the season to a more advance role in , his ice average time spiking from 18:47 to 20:41 per game 9. Cody Franson s minus 20 is the worst plus/minus rating on the Toronto Maple Leafs. He does not merit a top-4 place on this team this upcoming season, based on his play last season. The offense from the back-end can be more than made up for by Morgan Reilly, Jake Gardiner, and Dion Phaneuf, but Franson is currently too much of a defensive liability to be given top-four minutes. As such, Franson should not be paid as a top four defenseman. Franson has also not played a factor in helping the Leafs qualify for the postseason, has the Maple Leafs missed the playoffs last season. Franson is also not a proven playoff performer as of yet

6 II. VALID COMPARABLE PLAYERS A. Tyson Barrie - Colorado Avalanche - $2.6 Million Salary SEASON TEAM GP G A P +/- PIM PPG SHG GWG S S% AVALANCHE LAKE ERIE MONSTERS-AHL AVALANCHE LAKE ERIE MONSTERS-AHL AVALANCHE LAKE ERIE MONSTERS-AHL AVALANCHE NHL TOTALS Tyson Barrie is a 23-year old 5 10, right-hand shooting defenseman for the Colorado Avalanche who recorded 13 goals and 25 assists for 38 points in only 64 games during the NHL season 10. Barrie s points per game ratio in was 0.59 pts/game, while Franson recorded points at a rate of 0.42 pts/game 11. Furthermore, 76 % of Barrie s 25 assists were scored at even-strength, while 61% of Franson s assists were scored at even- strength 12. This stat suggests that Barrie is not only more defensively reliable than Franson with a plus-17 last season, he is puts up more offensive production at even-strength than Franson, a coveted and useful characteristic for a defenseman 13. The aforementioned stats also suggest that whereas Franson is a power play specialist, Barrie is a better all-round defenseman, who defends better, and who can score during even-strength situations. When Barrie was injured during the playoffs,

7 the Colorado Avalanche spiraled into elimination. The Colorado Avalanche were up 2-0 in the series against the Minnesota Wild when Barrie was injured during Game three. Colorado went on to win only one of the next 5 games, and went to lose the series 4-3. In summary, Tyson Barrie is better, younger, puts up more points, plays a more effective defensive game, and means more to his team than Cody Franson. Barrie is currently a more effective NHL defenseman than Franson in every sense and recently signed a 2 year deal for a cap hit of $2.6 million 14. B. Nick Leddy - Chicago Blackhawks -$2.7 Million Salary SEASON TEAM GP G A P +/- PIM PPG SHG GWG S S% BLACKHAWKS BLACKHAWKS ROCKFORD ICEHOGS-AHL BLACKHAWKS ISLANDERS NHL TOTALS Nick Leddy is a 23-yr old left-handed defenseman for the Chicago Blackhawks at the time of writing, he operates on their number two pairing behind Keith and Seabrook. Leddy has a cap hit of $2.7 million 15. He played 82 games last season, recording 7 goals and 24 assists for 31 points 16. His offensive production is thus comparable with the 33 points of Franson, but Leddy averaged 16:21 minutes TOI, almost 4 minutes less of ice time 17. Furthermore, Leddy only averaged 1:50 on the second

8 PP unit, scoring 10 PP points. 75% of Leddy s assists were recorded at even-strength, compared to the 39.3% of Cody Franson s points that were scored at even-strength 18. Nick Leddy is also more defensively responsible, finishing the season with a +10 rating. Leddy is also a former Stanley cup champion with the Chicago Blackhawks in Leddy offers more defensive stability at the back than Franson while producing similar rates of offensive production, despite playing fewer minutes. At 23 years old, a 4 full years younger than Franson, Leddy still has room to improve both his defensive and offensive game. C. Alec Martinez - Los Angeles Kings- $1.1 Million Salary SEASON TEAM GP G A P +/- PIM PPG SHG GWG S S% KINGS MANCHESTER MONARCHS-AHL KINGS KINGS TPS TURKU- FINLAND ALLEN AMERICANS-CHL KINGS KINGS NHL TOTALS Alec Martinez is a defenseman for the Los Angeles Kings who recorded 22 points in 61 games last season, a 0.36 pts/game ratio compared to the 0.41 pts per game ratio of Franson. Martinez has played 204 games for the Kings by the age of 26, and figures to be one of the pillars of their defense for the coming years. Martinez finished the season with a plus-17 rating, averaging 15:40 minutes per game, and 1:58 of power-play time on the second unit. His plus-17 rating was tied with

9 Doughty for the highest among Kings defenseman, and third among all King s forwards. Furthermore, Martinez s 11 goals was the most goals scored by a Los Angeles King defenseman last season, and his 2 game-winning goals were also tied for first among King s defenseman. Martinez has produced reliable defensive play, while being offensively productive at even-strength, recording 72% of his 22 points while five-onfive. Furthermore, Martinez was a Stanley cup winner with the Kings last season, while playing an active role during the playoff run. Martinez scored 5 goals and 5 assists for 10 points in 26 games with a plus-1 rating. Martinez s ice-time (16:36) and power-play time (2:16) increased from the regular season, indicating the coach s trust in Martinez as a reliable defenseman. In closing, Martinez provides effective scoring at even-strength, as well as scoring a substantial number of goals from the blue line. Martinez is defensively reliable as demonstrated by his plus-17 rating, and he is a Stanley cup winner from a playoff run in which he actively contributed. Furthermore, as demonstrated by Martinez s increase in ice-time during the playoffs, this is indicative of how the Kings plan to let Martinez role grow within the organization. Martinez is not the finished product, but neither is Cody Franson. However, Martinez has already proven himself during the highest echelon of professional hockey: the NHL Stanley cup finals, and he came out on top. III. CONCLUSION In conclusion, Cody Franson is undoubtedly a promising young NHL defenseman with much potential, and is a future number 4 defenseman for the Toronto Maple Leafs. 9

10 However at this moment, Franson does not bring enough to the team to warrant a $3.3million arbitration award. Franson s inconsistent offensive production and his defensive weakness are glaring holes in his game, which are not enough to outweigh his one-dimensional power-play production. Much better, more accomplished, younger allround defenseman, including Stanley cup champions are being paid less than 3.3 million, as demonstrated by the aforementioned comparable players. After analyzing Franson`s statistics in relation to comparable players, we can see that Franson is not as valuable or critical to the Maple Leafs current on-ice success as are other young defenseman to their teams. For this reason, Franson should be awarded a salary of $2.3 million. 10