Counting milestones for the death penalty

Question

When a character is resurrected using the Raise Dead ritual, she gets a death penalty:

The subject returns with a death penalty: –1 to all attack rolls, skill checks, saving throws, and ability checks. This death penalty fades after the subject reaches three milestones. [PHB1 311]

Now, a milestone is very clearly defined:

When the adventurers complete two consecutive encounters without stopping for an extended rest, they reach a milestone. [Rules Compendium 22]

My question is, does the death penalty require the milestones to be uninterrupted by extended rests?

E.g., if a resurrected character fights two battles (1 milestone), takes an extended rest, fights two more battles (1 milestone), spends a week at the spa and then engages in two more battles (1 milestone), does she lose her death penalty after that sixth fight?

Or does she have to fight six times in a row before going to bed, or it doesn't count?

Answer 1

does the death penalty require the milestones to be uninterrupted by extended rests?

No. It says three milestones, not three milestones without resting.

You get a milestone if you do two encounters without resting.

Encounter, Encounter, milestone achieved, Encounter, Encounter, milestone achieved, Rest, Encounter, Encounter, milestone achieved — makes three milestones.

(I don't think I've ever played a game where the party has gone through 6 encounters without a rest, they tend to deplete resources too much in the games I've played).

As an aside: Action points are gained when you reach milestones, but explicitly reset to one when you take an extended rest. The death penalty elimination count does not have this explicit reset, which seems to support the above argument.