What is the proper focus on a plaintiff's claim for damages arising from a motor vehicle accident?

In Michaelian v. State Comp. Ins. Fund, supra, 50 Cal.App.4th 1093, 58 Cal.Rptr.2d 133, the court further explained the proper focus in reviewing the sustaining of a demurrer to a similar action for declaratory relief, breach of insurance contract, and "bad faith" post-Montrose: "A complaint is to be 'liberally construed' in favor of potential coverage. [Citation.] Since pleadings are easily amended, the proper focus is on the facts alleged, rather than the theories for recovery. [Citation.] However, the insured " 'may not speculate about unpled third party claims to manufacture coverage.' " [Citation.]" (Michaelian, supra, 50 Cal.App.4th at p. 1106, 58 Cal.Rptr.2d 133.)

B. Pertinent Terms of the Policy at Issue