Where an insurer has elected to either defend under a reservation of rights or file a declaratory judgment action, the insurer may present evidence beyond the underlying complaint, so long as it does not tend to determine an ultimate issue in the underlying proceeding.The 7th U.S. Circuit Court of Appeals reversed a decision by U.S. District Judge Edmond E. Chang.Peter Hilger is the president of Allied Solutions LLC, a company that provides customized products to financial institutions. In 2013, Hilger was named as one of …