COMPLAINT FOR DECLARATORY RELIEF AND DEMAND FOR ...

11. Before introducing the Independent Contractor Agreement, Allstate hadmaintained that its agents had no ownership interest in the books of business that theagents themselves had developed. On the contrary, Allstate claimed exclusive ownershipof those books of business.12. To induce agents to enter into the Agreement, Allstate represented to agentsthat, as part of the Agreement, agents would obtain ownership in, and the opportunity tosell their books of business.13. Additionally, Allstate represented that agents would enjoy greater autonomyas independent contractors than they did as employees.14. Even after creating the independent contractor option in the 1990s, Allstatecontinued to apply its detailed work rules and requirements to all agents – employeeagents and independent contractor agents alike.B. Termination of all Agents Nationwide15. In November of 1999, Allstate announced its plan to terminate all of itsemployee agents.16. Under the forced termination, any agent who wished to continue as an Allstateagent would be required, among other things, to execute a Release of Claims AgainstAllstate and to enter a new Independent Contractor Agreement with Allstate.17. In order to induce agents to enter the Agreement following the announcedtermination of all employee agents, Allstate again represented to agents that, as part of