In Gehan Homes Ltd. v. Employers Mutual Casualty Co., 146 S.W.3d 833 (Tex. App.--Dallas 2004, pet. denied), the third-party claimants sued the insured for "past" bodily injuries and property damage. Id. at 846. The Fifth Court of Appeals court reversed the trial court's summary judgment and held that, given the court's obligation to construe the pleadings liberally and resolve any doubts in favor of coverage, the insurer failed to establish that "there was no allegation of a potential occurrence within the policy coverage period." Id. at 846. The insurers provided coverage to the homebuilder from June 30, 1997, through June 30, 1999. The homeowners sued the homebuilder but did not allege a date their injuries occurred. Id. at 845-46. The insurers moved for summary judgment on their duties to defend and indemnify the homebuilder. Id. at 837. In addition to arguing that the petition did not allege "bodily injury," "property damage," or an "occurrence," the insurers argued that the damage did not occur during the policy period. Id. at 839-46. The Court construed the pleadings liberally in favor of the insured and concluded that because the homeowners filed their lawsuit in May 2001 and claimed that they suffered "past" bodily injuries and property damages, the insurers did not establish as a matter of law that there was no allegation of a potential occurrence within the policy period. Id. at 846. The Court stated: "A movant is not required to specifically describe how evidence in support of the motion justifies a summary judgment; merely identifying a theory of liability or defense will suffice." In that case, the insurance company appellees did present the grounds but did not present arguments or authorities concerning two insurance exclusions in their motions for summary judgment to establish that the policy exclusions applied to the insured's claims, which would preclude their duty to defend. 146 S.W.3d at 845. The insured argued that, because of the insurers' lack of argument and authorities concerning these two exclusions at trial and on appeal, we should not consider the two exclusions on appeal. Id. The Court concluded, citing other authority, that a movant "merely" needs to identify a theory of liability or defense and is not required to specifically describe how the evidence supporting the motion justifies summary judgment. Id.