If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN COURT OF APPEALS

RUSSELL LOIOLA, a legally incapacitated person, UNPUBLISHED by JEFFREY FRIED, Personal Representative, August 6, 2020 Plaintiff-Appellee, v No. 348670 Washtenaw Circuit Court CITIZENS INSURANCE COMPANY OF LC No. 16-001044-NF AMERICA, Defendant, and CITIZENS INSURANCE COMPANY OF THE MIDWEST, Defendant-Appellant.

Before: METER, P.J., and BECKERING and O’BRIEN, JJ.

BECKERING, J. (concurring).

I concur in the result only.

/s/ Jane M. Beckering

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