Read the following excerpt from a US court opinion:
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at 406, 79 Cal.Rptr.2d 52. NCAIG raises a separate issue, barely addressed by Maxum, as to whether Max-um breached its duty to defend Mulberry in the underlying litigation. The Policy states: We will have the right and duty to defend any “insured” against any “suit” seeking those “damages”. However, we will have no duty to defend an “insured” against any “suit” seeking “damages” for a “wrongful act” to which this insurance does not apply. In NCAIG’s view, because the Maxum failed to show that Mulberry subjectively believed that the issuance of the fraudulent insurance would result in a claim, it also breached its duty to defend the litigation, and is therefore liable for the default judgment. See Gray v. Zurich Ins. Co., 65 Cal.2d 263, 279, 54 Cal.Rptr. 104, 419 P.2d 168 (1966) . The next inquiry is whether the knowledge of
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What is the most suitable continuation to the opinion? Your options are:
A. holding that insurance companies that breach the duty to defend to be liable on any subsequent judgment
B. holding that an insurer had no duty to defend in the absence of any cause of action amounting to a potentially covered offense under the  insurance policy
C. holding government could be liable for breach of a contractual obligation to purchase insurance for plaintiff
D. holding the duty to indemnify is narrower than the duty to defend
E. holding that insurer had a continuing duty to defend
Reply with [A, B, C, D, E] only.