What is the defence in a personal injury action brought by a plaintiff in her Primerica business case?

The defendant submits that the plaintiff’s future loss of income is minimal. The submission is two-fold: factually, the defendant submits that the plaintiff is able to carry on her Primerica activities presently, notwithstanding the injuries suffered in the accident; legally, that is, as a matter of proof, the defendant submits that the plaintiff has failed to carry the burden of establishing a loss of future income earning capacity. The latter submission is made with reference to Athey v. Leonati, 1996 CanLII 183 (SCC), [1996] 3 S.C.R. 458 at para. 27, to the effect that purely speculative claims will not give rise to compensation for loss of future income earning capacity; and Perren v. Lalari 2010 BCCA 149, to the effect that a plaintiff must always prove that there is a “real and substantial” possibility of a future event leading to income loss. The defendant submits that the plaintiff has failed to prove such a possibility.