For Whom the Statute Tolls? Not Without Actual Evidence for this Plaintiff

In Krystyna Reid v Progressive Michigan Insurance Company, the Court addresses and clarifies the amendment to MCL 500.3145 and the “tolling provision.” The Court of Appeals in essence “split the baby” finding the preamendment version of MCL 500.3145(1) bars her claims that accrued before June 11, 2019, while the current version of that statute bars her claims that accrued between June 11, 2019 and November 3, 2019 because the Plaintiff failed to provide “specific” proof such as statements, bills, contracts or logs or even testimony that the services were rendered. Counsel should continue to press for such proofs from Plaintiffs and if non-existent, consider filing motions to bar such claims under MCL 500.3145(3).

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