The proposed amended complaint alleges that Grace negligently failed to fill in a trench on the side of the road two days prior to the motor vehicle accident in which plaintiff was injured, that Grace parked construction vehicles by the roadway, and that its personnel joked around when they signed into a safety meeting. This conduct, if proven, is insufficient for the imposition of punitive damages, because it cannot be viewed as a conscious and deliberate disregard of the...
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