Can an insurer providing a defense, even though subject to reservation rights, intervene in the action?

^9. Under California law, "an insurer providing a defense, even though subject to a reservation of rights, may intervene in the action" because California Insurance Code 11580 "provides that a judgment creditor may proceed directly against any liability insurance covering the defendant, and obtain satisfaction of the judgment up to the amount of the policy limits." Gray v. Begley, 182 Cal. App. 4th 1509, 1522-24 (2010). But see Hinton v. Beck, 176 Cal. App. 4th 1378, 1384 (2009) ("an insurer who denies coverage and refuses to defend its insured does not have a direct interest in the litigation between the plaintiff and the insured to warrant intervention." (emphasis added)).