Republic of the Philippines

REGIONAL TRIAL COURT

THIRD JUDICIAL REGION
Branch 44
City of San Fernando, Pampanga

THE PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 28464

Plaintiff,
-for-
-versus-
“VIOLATION OF SECTION 5, ARTICLE II
OF RA 9165”

ALDINE DELA CRUZ y MONTOYO

alias ”DAN”,
Accused.
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MOTION TO ALLOW ACCUSED TO SEEK

IMMEDIATE MEDICAL ASSISTANCE

ACCUSED, assisted by the undersigned counsel, most respectfully states

that:

1. In a letter dated February 26, 2024, Provincial Warden Alain P. De Leon,

informed the undersigned counsel that accused has been experiencing
episodes of dizziness and blurriness of vision of both of his eyes for almost
a week now;

A copy of the Letter from the Office of the Provincial Warden dated
February 26, 2024 is attached as Annex “A” and is made an integral part
hereof;

2. According to the said letter, accused is requesting to be allowed to seek

medical attention with proper security escort on March 1, 2024 at around
8:00 a.m. in Jose B. Lingad Memorial General Hospital;

3. However, due to the time of receipt of the letter and time constraints
caused by the busy schedule of counsel, the instant motion can only be
filed as of date;

PRAYER

WHEREFORE, in view of the foregoing, accused ALDINE DELA CRUZ y

MONTOYO alias ”DAN” most respectfully pray upon the Honorable Court to be
allowed to seek medical assistance as soon as possible.

Other reliefs just and equitable in the premises are likewise sought.

Angeles City, Pampanga, March 1, 2024

ATTY. ANNA LEE K. GOMES

Counsel for the Accused