In the Court's view, the risk that evidence of insurance coverage would be introduced at Trial, that the issue of the insured's liability would be removed from the adversarial context, and that excess insurers would be unfairly prejudiced, were considerations which outweighed any public policy in encouraging settlements, and in equalizing an insured's bargaining power. Id. at 1112, 7 Cal.Rptr.2d at 136; see also, Somerset South Properties v. American Title Ins., 873 F.Supp. 355, 358 (S.D.Cal.1994) (applying California law, the Court invalidated an insured's assignment of its claim against its insurer, since the insured and assignee had entered into a stipulated Judgment with a covenant that the assignee would not execute the Judgment against the insured); Rose v. Royal Ins. Co., 2 Cal.App.4th 709, 715, 3 Cal.Rptr.2d 483, 486 (1992) (enforcing a no-action clause on the ground that a Judgment obtained in the settlement of a claim would not protect an insurer against collusion), rev. denied (Cal., Feb. 27, 1992). Since Smith, however, the California Courts of Appeal appear to have moved their focus from the validity of the assignment to a consideration of whether the Judgment was fair and reasonable, and otherwise free from fraud and collusion.