Former Bandidos enforcer Toby Mitchell no longer associates with bikie gangs and fears being attacked again if he is sent to prison, a Melbourne court has heard.
Mitchell was on the "edge of death" after he was shot five times in the back outside a Brunswick gym in 2011 and has suffered significant health effects as a result, the Victorian County Court heard on Tuesday.
The former Bandidos sergeant-at-arms has pleaded guilty to affray over a wild nightclub brawl in central Melbourne in November 2010.
A pre-sentencing hearing was told 39-year-old Mitchell - as well as Savvacis Tsivicios, 41, of Taylors Lakes, and Peter Robert Algie, 43, of Southbank - punched staff and threw bar chairs after being asked to leave the Centrefold Lounge on King Street.
Defence barrister Christopher Dane QC described the incident as a "blue".
He said Mitchell had suffered serious kidney damage and post-traumatic stress disorder since the shooting.
"This is a mature man who has had a substantial interference with his life since the offence occurred," Mr Dane said.
Mitchell was again shot in March last year after more than 30 rounds were fired at a Melton bikie clubhouse. He was shot in the right arm.
Mr Dane said Mitchell was no longer a member of any gang or club and was concerned that other inmates would seek to attack him if he was sent to prison.
"He has a justifiable fear of entering the prison system," he said.
Prosecutor Mark Rochford SC said the nightclub incident was a violent and vicious attack that was completely unjustifiable on any basis.
"There was absolutely no reason for it to have taken place," he said.
Judge John Smallwood will sentence the three men on Wednesday morning.
