COMPLAINT FOR DECLARATORY RELIEF AND DEMAND FOR ...

45. The Agreement and all related documents are silent concerning any obligationof the agent of provide check reading or other banking services for Allstate at the agent’sexpense.COUNT IBREACH OF CONTRACT(Seeking a Judicial Declaration that Allstate May Not Restrictor Prohibit Sales of Books of Business by Imposing HeightenedRequirements for Approval)46. The Agreement provides Allstate agents, including NAPAA’s agent membersin Florida, an ownership interest in their books of business.47. The Agreement recognizes an agent’s right to sell his or her interest in thebook of business, including transfers to existing Allstate agents, upon receiving priorapproval from Allstate.48. The Agreement, by reference to the express standards set out in the manual,sets forth specific requirements which must be met before a sale may be made to aprospective purchaser.49. Allstate has, both nationally and specifically in Florida, made statementsindicating that it has heightened the express requirements that must be met by existingAllstate agents who seek to purchase another agent’s book of business.