COMPLAINT FOR DECLARATORY RELIEF AND DEMAND FOR ...

50. Allstate has, both nationally and specifically in Florida, made statementsindicating that it will not, as a general rule, approve sales of books of business to existingAllstate agents.51. Allstate has, both nationally and specifically in Florida, refused to approvesales of books of business either because the proposed purchaser is, in fact, an existingAllstate agent or because the proposed purchaser does not meet the heightenedrequirements Allstate has set forth.writing.52. Typically, Allstate will not put the basis for its refusal of a proposed sale in53. Plaintiff disputes Allstate’s position that it may unilaterally modify therequirements necessary for a sale of a book of business and contends that thismodification represents a breach of the Agreement.54. As a result of Allstate’s unilateral modification of the requirements fortransferring the book of business, all Allstate agents, including NAPAA’s agent membersin Florida, have suffered and will continue to suffer injury.55. The heightened standards have shrunk the pool of potential purchasers therebyimpeding agents’ ability to sell their books of business for fair value, if at all.56. Additionally, the heightened requirements have deprived a number of Allstateagents the opportunity to acquire additional books of business.