Read the following excerpt from a US court opinion:
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insurance contract [does] not impose a duty on the insurer to pay attorney’s fees in connection with the insured’s pursuit of the coverage issues.Generally, if the insured hires an attorney to represent him in coverage disputes, he will have to bear those costs himself.” Steptore v. Masco Constr. Co., 643 So.2d 1213, 1218 (La.1994); see Dowden v. Leebo’s Stores, Inc., 877 So.2d 353, 356 (La.Ct.App.2004) (“Generally, an insured can recover attorney fees associated with its defense of the underlying action, but not with its litigation of the coverage issue.”). Some Louisiana courts have, however, allowed for the imposition of attorney’s fees and penalties pursuant to Louisiana Revised Statute §§ 22:658 and 22:1220. See, e.g., Credeur v. McCullough, 702 So.2d 985, 987 (La.Ct.App.1997) . But see, e.g., Howell v. Am. Cas. Co. of
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What is the most suitable continuation to the opinion? Your options are:
A. holding that attorneys fees can be awarded only from time duty to defend arose
B. holding insurers duty to defend is determined by allegations in the petition
C. holding that awarded fees were reasonable and that proof that attorneys fees are necessary apart from testimony as to the reasonableness of the fee is not required
D. holding trial court did not abuse its discretion when it awarded attorneys fees because the declaratory relief action addressed validity of note and was not used as a mere ploy to recover attorneys fees
E. holding that a thirdparty claimant could be awarded attorneys fees and penalties pursuant to  221220 because the insurers failure to defend was arbitrary and capricious
Reply with [A, B, C, D, E] only.