The trial court, therefore, is permitted to keep discovery within reasonable limits and avoid “open-ended fishing expeditions” or harassment to ensure that discovery contributes to the orderly dispatch of judicial business. Robbins v. Kalwall Corp., 120 N.H. 451, 453, 417 A.2d 4 (1980); Hartford Accident &c. Co. v. Cutter, 108 N.H. 112, 114, 229 A.2d 173 (1967); Riddle Spring Realty Co. v. State, 107 N.H. 271, 278, 220 A.2d 751 (1966). NHBB argues that the nature of electronic trade secrets requires particularly broad discovery.

New Hampshire law favors liberal discovery, Yancey v. Yancey, 119 N.H. 197, 198, 399 A.2d 975, 976 (1979), and the trial court has broad discretion in controlling its scope, Scontsas v. Citizens Insurance Co., 109 N.H. 386, 388, 253 A.2d 831, 833 (1969). This court has recognized that "discovery is an important procedure `for probing in advance of trial the adversary's claims and his possession or knowledge of information pertaining to the controversy between the parties. [The] underlying purpose is to reach the truth . . . .'" Id. at 388, 253 A.2d at 832-33 (quoting Hartford Accidentc. Co. v. Cutter, 108 N.H. 112, 113, 229 A.2d 173, 175 (1967)). The record discloses that prior to trial, the defendant moved to compel the plaintiffs (1) to disclose the identity of Dr. Abroms, the physician who examined Cain in Worcester, Massachusetts, after the collision; (2) to provide the defendant with Dr. Abroms' medical records and copies of the statements of the two boys who were bicycling with Cain at the time of the accident, and of the investigating officer, that were taken by the plaintiffs' counsel shortly after the collision; and (3) to pay the cost of additional depositions of the plaintiffs concerning the examination and treatment of Cain by Dr. Abroms.

Withrow v. Larkin, 421 U.S. 35, 47 (1975). [5, 6] Although discovery rules are to be given a broad and liberal interpretation, see Robbins v. Kalwall Corp., 120 N.H. 451, 417 A.2d 4 (1980), the trial court has discretion to determine the limits of discovery, see Hartford v. Cutter, 108 N.H. 112, 115, 229 A.2d 173, 176 (1967). Because the defendant has not made any actual allegations of bias, the information sought does not appear "reasonably calculated to lead to the discovery of admissible evidence."

McElroy v. United Airlines, Inc., 21 F.R.D. 100, 102 (W.D. Mo. 1957); 4A J. Moore, Federal Practice § 33.29 [2] (2d ed. 1975); 8 C. Wright A. Miller, Federal Practice and Procedure § 2181, at 577-78 (1970) citing Advisory Committee Note to Rule 33(b). However, the purpose of interrogatories is to narrow the issues of the litigation, Sawyer v. Boufford, 113 N.H. 627, 312 A.2d 693 (1973); Hartford Accident Co. v. Cutter, 108 N.H. 112, 229 A.2d 173 (1967); F. James, Civil Procedure § 6.4, at 190 (1965), and prevent unfair surprise by making evidence available in time for both parties to evaluate it and adequately prepare for trial. McDuffey v. Boston Maine R.R., 102 N.H. 179, 152 A.2d 606 (1959).

The issue, which is of first impression in this jurisdiction, is whether a defendant in a personal injury and wrongful death action must disclose his financial situation on deposition prior to trial in order to apprise the plaintiff of his ability to respond to a verdict in excess of his insurance coverage. The underlying purpose of discovery, whether by means of depositions, interrogatories or pretrial hearings is to reach the truth and to reach it as early in the process as possible by narrowing the issues pertaining to the controversy between the parties. Hartford Accident c. Co. v. Cutter, 108 N.H. 112, 113, 229 A.2d 173, 175 (1967). Another important object of such procedures, especially in these days of crowded dockets, is to enhance the chances for a fair and amicable settlement.

The Trial Court may permit discovery over this objection if the evidence sought would aid the party either in his own case or in defending against the case of the other party. Riddle Spring Realty Co. v. State, 107 N.H. 271; Scontsas v. Citizens Ins. Co. 109 N.H. 386. See Hartford Accident c. Co. v. Cutter, 108 N.H. 112. The immovable object resistance to discovery with intermediate appeal to this court does not advance the law of discovery.

[The] underlying purpose is to reach the truth. . . ." Hartford Accidentc. Co. v. Cutter, 108 N.H. 112, 113. It is the philosophy of the adversary system that the truth will more likely be reached if both sides of the issue are fully presented and that this is more likely to occur if the sides are presented by partisan advocates.

Dougherty v. Gellenthin, 99 N.J. Super. 283; Combellick v. Rooks, (Mo.) 401 S.W.2d 460. We have recently held that a statement of the defendant assured made to the insurer's agent shortly after the accident was not exempt under the work product rule (Hartford Accident c. Co. v. Cutter, 108 N.H. 112) and neither is this transcript. Plaintiff argues further that in the absence of a transcript and any affidavit under Superior Court Rule 47, there is no evidence to sustain the discretionary rule of the Trial Court. Superior Court Rule 47 provides in part that the court "will not hear any motion grounded upon facts, unless they are verified by affidavit, or are apparent from the record.

The probable availability to Consolidated of the results of an immediate and apparently thorough investigation made shortly after the fire would tend to lessen materially any claim of prejudice to plaintiff because of delayed notice. Hartford Accident c. Co. v. Cuttler, 108 N.H. 112. We hold that under all the circumstances existing both when the fire occurred and when the notice was given, including the length of the delay in giving notice, the reasons for it, and the probable effect of the delay on the insurer, the Trial Court properly found and ruled that notice was given "as soon as practicable" within the conditions of the policy.