Petitioner Adrian Fridman (“Fridman”) was injured in an automobile accident involving an underinsured motorist. Fridman filed a claim with his uninsured/underinsured (UM) insurance carrier (Insurer) for the $50,000 limits of his UM policy. After the Insurer refused to pay the policy limits, Fridman filed a complaint against the Insurer to determine liability under the UM policy and the full extent of his damages. One month before trial, the Insurer tendered a check to Fridman for $50,000 and filed a confession of judgment for that amount seeking entry of the confessed judgment and a dismissal. Fridman opposed the entry of a confessed judgment, arguing that a jury verdict would determine the upper limits of Insurer’s potential liability under a future bad…