You are a paralegal for a defense firm that defends personal injury claims involving car accidents. Your client is being sued for a car accident in which the client rear ended the Plaintiff who was stopped at a red light. Plaintiff alleges permanent and serious neck and back injuries and wants compensation for the injuries and lost wages. We have served Interrogatories on the Plaintiff on August $1,2021.$ When we received no response after $30$ days, a good faith email and letter were sent to Plaintiff's counsel on $9/2/21$ asking for the overdue discovery response. We received no response from Plaintiff's counsel.