Seller of used car, who had fraudulently represented to buyer that the vehicle identification number (VIN) had been scratched out under windshield because former owner had been trying to prevent repossession of the car, was liable to buyer for punitive damages, based on having acted willfully or with reckless disregard for the consequences of the seller's conduct, even if the seller had not known the car had been "chop shopped" from two different vehicles.