situation was appreciably changed for the worse during the five-month period of delay. We do not find persuasive TMLT’s argument that a bill of review is, by definition, excluded from an insurer’s duty to defend because a defective-service default judgment, though void, nonetheless becomes final thirty days after entry, thereby ending the lawsuit. A judgment may be final for purposes of appeal but still open to direct attack. Even if the language of a policy requiring an insurer “to defend any lawsuit” against the insured does not explicitly require an insurer to seek post-judgment relief, it is illogical to suppose that the word “defense” relates only to the trial of the action and does hot embrace such relief. See 22 Eric M. Holmes, Holmes’ Appleman on Insurance § 136.11 (2d ed.2003) (<HOLDING>). While the Texas Supreme Court has not
holding that an insurers duty to defend pursuant to an insurance contract arises whenever the complaint filed by the injured party may potentially come within the policys coverage holding that an insurers duty to defend arises from the allegations in the complaint against the insured holding that an insurers obligation to defend an insured was a property interest subject to prejudgment attachment holding insurers duty to defend is determined by allegations in the petition recognizing that by that reasoning an appeal is likewise not a defense by definition but is nonetheless in some circumstances encompassed within an insurers duty to defend