AFLAC sells health care insurance policies. Darren Galgano signed an "Associate's Agreement" with AFLAC, which engaged Galgano to solicit applications for insurance policies offered for sale by AFLAC. The agreement also states that Galgano is an independent contractor, without the authority to bind AFLAC for Galgano's
"debts, faults, or actions." The agreement specifically states that Galgano is prohibited from entering into contracts or incurring debt on behalf of AFLAC.

Galgano became a "District Sales Coordinator's Agreement," which incorporated the terms of the "Associate's Agreement" and specifically withheld authority from Galgano to "rent any office space or telephone, open any bank account, or make any expenditure, obligation or commitment for any purpose in the name of AFLAC without specific written authorization from the president, a vice president, or secretary of AFLAC." When Galgano became a "Regional Sales Coordinator's Agreement," he signed a "District Sales Coordinator's Agreement," which incorporated the terms from the previous agreements.

Galgano leased retail property located in Crestwood, Illinois, from Cove Management. The first page of the lease listed Cove as the lessor, listed "AFLAC" as the tenant, and listed Galgano as the guarantor. The lease provided that the permitted use of the space was "insurance services." On the signature page, Galgano signed his own name under "lessee" and "guarantor." He did not indicate on the signature page that he was signing on behalf of AFLAC.

After Cove was not paid rent and the property in Crestwood was abandoned, Cove filed suit for breach of the lease agreement against both AFLAC and Galgano. Can AFLAC be held liable? [Cove Management v AFLAC, Inc., 986 N.E.2d 1206 (Ill. App. 2013)]