Does a plaintiff have to amend or amend the causes of action in response to a claim for bodily injury or property damage?

Gunderson v. Fire Ins. Exchange (1995) 37 Cal.App.4th 1106, 44 Cal.Rptr.2d 272, is also distinguishable. There, the insureds were served with an action entitled " 'complaint to quiet title to real property, for declaratory relief, and for injunctive relief,' " in which plaintiff sought only to enjoin the insureds from using a portion of her property as an easement. After reviewing the complaint, the insurer refused to defend because the causes of action "contained 'no reference to a claim for bodily injury or property damage.' " (Id. at p. 1110, 44 Cal.Rptr.2d 272.) Likewise, neither the first amended complaint nor the insureds' answer referred to bodily injury or property damage. Nearly one year after the insurer declined the defense, plaintiff advised the insureds' attorney they were cutting trees and committing destructive acts on her property. The complaint was not amended, however, and the case settled before trial without the insurer ever having been advised of any claim of actual, or potential, property damage.