COMPLAINT FOR DECLARATORY RELIEF AND DEMAND FOR ...

(“NAPAA”) needs a declaration from this Honorable Court that Allstate’s conductrepresents a breach of, and is inconsistent with, the terms of Allstate’s Agreement withNAPAA’s agent members in Florida.II.THE PARTIES6. The National Association of Professional Allstate Agents is a not-for-profitprofessional trade association incorporated in New York with headquarters in Michigan.NAPAA has members nationwide, including members throughout Florida.7. The Allstate Insurance Company is an Illinois corporation with headquartersin Illinois. Allstate does business throughout the State of Florida.8. This Court’s jurisdiction in this matter arises under 28 U.S.C. §1332(a)(1) and28 U.S.C. §2201. Venue is proper under 28 U.S.C. § 1391(a)(1) and (2).III.FACTUAL BACKGROUNDA. Allstate’s Contractual History with its Agents9. For decades, Allstate hired its insurance agents as employees of thecompany. These employee agents worked under written contracts with Allstate.10. Beginning in the 1990s, Allstate began encouraging its employee agents toterminate their employee status and enter into an Independent Contractor Agreement withAllstate. A number of agents elected to do so, but many did not.