In law, interrogatories (also known as requests for further information)[1] are a formal set of written questions propounded by one litigant and required to be answered by an adversary in order to clarify matters of fact and help to determine in advance what facts will be presented at any trial in the case.
However, in most cases, the parties will require additional information to fully understand each other's legal and factual claims.
To prove negligence, the law requires the injured plaintiff to show that the driver owed them a duty of care and breached it, causing the injury.
Assuming that the defendant did not dispute driving a vehicle that was involved in the accident that injured the plaintiff, the case would come down to whether the driver drove in accordance with the standard of a reasonable driver, and whether the injured person's injuries are a foreseeable consequence of the driving.
If the plaintiff alleges that the defendant failed to control the car properly or failed to pay proper attention to the road and other vehicles, the plaintiff could ask interrogatory questions that would help prove those allegations or require disclosure of the basis of any denial of negligence by the defendant.
The driver may have a defense to those allegations, perhaps if the accident occurred at low speed, and was unavoidable (maybe due to some third party intervention).
Whether the judge will make an order is discretionary and will be determined in accordance with the overriding objective, and in the context of the questions asked.
[6][7] However, because the declaration of necessity must be executed under penalty of perjury, it can expose an attorney to personal sanctions for propounding an excessive number of harassing and burdensome interrogatories.