REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION

Municipal Trial Court
xxx

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus - Crim. Case No. xxx

xxx,
Accused.
x------------x
Motion
Accused, xxx, thru the undersigned Public Attorney and unto this
Honorable Court, most respectfully avers that:

1.) Accused, xx, is currently detained in xxx Provincial Jail, xxx;

2.) He has been examined at xxx due to Upper Gastro Intestinal

Bleeding Sec. to Bleeding Peptic Ulcer Disease and Lower
Gastro Intestinal Bleeding Sec. to External Hemorrhoids last
March 6, 2017;

3.) Accordingly, xxx of xxx Memorial Hospital who examined

him, recommended that he should undergo further treatment
and needs to be confined for at least 5 days in the xxx
Memorial Hospital;

4.) He was likewise scheduled for endoscopy on March 13, 2017;

5.) However, he was not fit for transport on the dates stated
above. In this regard, we are asking for another chance for him
to undergo medical check-up and/or procedure on July 20,
2017;

IN VIEW OF THE FOREGOING, it is most respectfully prayed that

accused xxx be allowed to undergo further treatment. It is likewise
prayed that the Provincial warden be ordered to bring the accused to
the James L. Gordon Memorial Hospital on July 20, 2017 for him to
undergo medical check-up and/or procedure.

Other reliefs just and equitable under the premises are likewise prayed
for.

Respectfully submitted.

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Iba, Zambales. July 17, 2017.

Department of Justice
PUBLIC ATTORNEY’S OFFICE
xxx District Office
xxx

By:

Atty. xxx
Public Attorney I
Roll No. xxx

To the Clerk of Court;

MTC, xxx;

Greetings!

Please submit the foregoing motion immediately upon receipt hereof

for the consideration and approval of the Honorable Court without
further oral arguments.

Thank you.

Atty. xxx

Copy furnished:

Pros. xxx
Assistant Provincial Prosecutor
Office of the Provincial Prosecutor
Hall of Justice, xxx

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