Colorado Code § 38-30-122

No action against warrantor without notice and refusal to defend. No
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right of action shall exist upon a covenant of warranty against a warrantor when possession of
the premises warranted has been actually delivered to or taken by the warrantee, until the party
menacing the possession of the grantee, his heirs, personal representatives, or assigns have
commenced legal proceedings to obtain possession of the premises in question and the grantor,
after notice, has refused to defend, at his own cost, the premises in such action.

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