<Punitive Damages>

The Plaintiff can also seek punitive damages in addition to pecuniary damages and non-pecuniary damages, if defendant’s impaired driving caused significant injuries in the MVA.
What can be added in Plaintiff’s statement of claim:

(a) The Defendant, Stephen Stuart drank excessively;

(b) he was driving at an excessive speed while intoxicated;

and (c) he showed a conscious and reckless disregard for safety and lives of others.