COMPLAINT FOR DECLARATORY RELIEF AND DEMAND FOR ...

76. 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.77. Allstate made these representations expecting that Allstate agents would relyon said representations and for the purpose of inducing Allstate agents to enter into theAgreement.78. Allstate agents, including NAPAA’s agent members in Florida, did rely onthose representations and were induced by those representations to enter into theAgreement. As a result of Allstate’s unilateral modification of the requirements forselling the book of business to an existing Allstate agent, all Allstate agents, includingNAPAA’s agent members in Florida, have suffered and will continue to suffer injury.WHEREFORE, Plaintiff seeks a declaration by the Court that Allstatefraudulently induced its agents to enter the Agreement.COUNT IVBREACH OF CONTRACT(Seeking a Judicial Declaration that Allstate May NotUnilaterally Modify the Agreement by Adding or Increasing Production Quotas)