Read the following excerpt from a US court opinion:
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defend, despite controlling authority that the duty to defend is determined by allegations of the underlying complaint, because further factual development was warranted to determine whether damage, as alleged in the complaint, occurred while the premises were being used as contemplated by the policy); American States Ins. Co. v. Maryland Casualty Co., 587 F.Supp. 1549, 1553 (E.D.Mich.1984) (declaratory judgment action by insurer where, despite state authority that the duty to defend is determined based on allegations of the complaint, court looked to “subsequent discovery and testimony at trial” to discern the “continuous nature of the insured’s dumping” and held that the insurer had no duty to defend or indemnify); Kepner v. Western Fire Ins. Co., 109 Ariz. 329, 509 P.2d 222 (1973) ; Barmet of Indiana v. Security Ins. Group, 425
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What is the most suitable continuation to the opinion? Your options are:
A. holding insurers duty to defend is determined by allegations in the petition
B. holding that the insurer had no duty to defend the insured because the allegations of the initial complaint did not allege facts which would bring the case within the coverage of the title insurance policy
C. holding despite authority for the general proposition that the duty to defend is determined based on the allegations of the complaint that an insurer had no duty to defend where the underlying claim was covered by the policy based on the facts pleaded in complaint but other facts not appearing in the complaint excluded coverage
D. holding that an insurers duty to defend arises from the allegations in the complaint against the insured
E. holding that the trial court erred in looking beyond the allegations of the complaint to determine whether a duty to defend arose
Reply with [A, B, C, D, E] only.