COMPLAINT FOR DECLARATORY RELIEF AND DEMAND FOR ...

59. The Agreement provides Allstate agents, including NAPAA’s agent membersin Florida, an ownership interest in their books of business.60. 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.61. 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.62. 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.63. 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.64. 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.65. Typically, Allstate will not put the basis for its refusal of a proposed sale in