Shaw Construction, LLC v. United Builder Services, Inc.

Opinion by

Judge WEBB.

1 1 In this interlocutory appeal, we decide two questions of first impression under the Construction Defect Action Reform Act, see-tions 13-20-8011, et seq., C.R.S.2011l ("CDARA"). First, section 13-20-805, C.R.S.2011 ("section 805"), tolls construction defect claims against only parties who receive actual notice of a claim. Second, in applying the statute of repose, section 13-80-104, C.R.9.2011 ("section 104"), to a multiphase construction project, an improvement may be a discrete component of the larger project, which can be substantially completed before the entire…