COMPLAINT FOR DECLARATORY RELIEF AND DEMAND FOR ...

FRAUDULENT INDUCEMENT(Seeking a Judicial Declaration that Allstate FraudulentlyInduced Allstate Agents to Enter the Independent Contractor Agreement)70. In promoting the Agreement within the Preparing for the Future booklet andelsewhere, Allstate represented to its agents that, if they entered into the Agreement, theywould acquire an ownership interest in their books of business.71. Allstate further represented that, if the agents entered into the Agreement,they would be able to sell their newly acquired interest to third parties, including existingAllstate agents.72. Allstate reiterated these representations within the Agreement itself.73. At the time of making these representations, Allstate knew that it did notintend to allow sales as represented.74. Allstate has, both nationally and specifically in Florida, made statementsindicating that it has heightened the specific requirements that must be met before a saleof a book of business may be made to a prospective purchaser.75. 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.