Illinois Appellate Court
Civil Court
Insurance
Insurer filed declaratory judgment action seeking declaration that commercial developer was not an additional insured under policy it issued for construction company, a co-defendant in personal injury action. Trial court lacked jurisdiction to enter default judgment order in absence of developer's insurer, where judgment materially affected its rights. Court was within its discretion in allowing developer's insurer to intervene in reopened action by insurer. (CONNORS and CUNNINGHAM, concurring.)