Progressive Michigan Ins. Co. v. Espinoza-Solis and
Shkreli
No. 366764, 2024 WL 3075088 (Mich. Ct. App. June 20, 2024)
The Michigan Court of Appeals affirmed summary judgment for
Defendant Gjovalin Shkreli (Shkreli), holding that Progressive
Michigan Insurance Company (Progressive) must pay him up to the
statutory minimum liability benefits of $250,000, despite the
non-cooperation of Progressive's insured, Juan-Carlos
Espinoza-Solis (Espinoza-Solis).
Defendants Espinoza-Solis and Shkreli were involved in an
automobile accident on June 23, 2021 and Shkreli filed a negligence
action against Espinoza-Solis. Espinoza-Solis maintained a Michigan
No-Fault automobile insurance policy with Progressive, which
retained counsel to defend him in the negligence action. After a
breakdown in the attorney-client relationship, the retained counsel
for Espinoza-Solis withdrew as his counsel. Shkreli then filed a
motion for entry of default judgment, which the trial court
granted,
