Primo’s failure to allege or introduce evidence of damages separate and apart from the loss of his benefits under the contract. But Great American filed only a traditional motion for summary judgment, and therefore it had the burden to prove that no genuine issues of material fact existed regarding Primo’s entitlement to exemplary damages. Compare Rule 166a(c) with Rule 166a(i). Only then would the burden shift to Primo to produce evidence that would raise a genuine issue of fact regarding his entitlement to exemplary damages. Lyda Swinerton Builders, Inc., 409 S.W.3d at 229. Having failed to carry its own burden, Great American cannot shift the burden to Primo to produce evidence to support a separate distinct tortious injury with distinct actual damages. See Brown, 20 S.W.3d at 159 (<HOLDING>). Because Great American failed to show that
holding that on appeal a nonmovant need not have answered or responded to the motion for summary judgment to contend that the movants summaiy judgment proof is insufficient as a matter of law to support summary judgment holding that nonmovants failure to except or respond cannot supply by default the grounds for summary judgment or the summary judgment proof necessary to establish the movants right holding that a motion to dismiss or for summary judgment precluded default judgment holding that trial court may not grant summary judgment by default  when the movants summary judgment proof is legally insufficient holding that the parly opposing summary judgment must do more than merely suggest possible error in the movants summary judgment evidence he must submit facts which demonstrate that the movants summary judgment evidence is questionable or that the movants allegations are not properly supported