Plaintiffs case, and the district court correctly held that the post-1972 insurance plans did not require Defendant to cover Plaintiffs legal costs in the underlying lawsuit. II. PMA’S OBLIGATION TO REIMBURSE MUELLER FOR THE REASONABLE COST OF SETTLING THE UNDERLYING LAWSUIT In addition to its claim that Defendant was obligated to provide it with legal defense in the underlying lawsuit, Plaintiff also claims that Defendant must indemnify it for the costs of settling that suit. As discussed above, however, the policies at issue in this case do not cover the underlying lawsuit. Furthermore, Plaintiff bears a more difficult burden to demonstrate that it has a right to indemnification under these policies than it bore with respect to its claim seeking defense. See Gedeon, 188 A.2d at 322 (<HOLDING>). Accordingly, the district court correctly
holding the obligation to defend does not arise until the insurer is presented with a complaint holding that there may be an obligation to defend under an insurance policy even though there is no obligation to indemnify holding that an insurers obligation to defend an insured was a property interest subject to prejudgment attachment holding where there is no duty to defend there is no duty to indemnify holding that insurance obligation was primary to indemnity obligation