A former Hells Angels member who plotted with his son to slay a high-ranking Sydney bikie had feared for his life, a judge has been told.
Wade Basanovic fired the fatal shots and wounded an innocent bystander but it was his father, Michael Basanovic, who instigated the plot and it was his gun used in the crime.
The son and his father said that just before the shooting the victim told them: "You're all f***ing dead", according to an agreed statement of facts before the NSW Supreme Court.
Michael Basanovic, 54, faced a sentence hearing on Wednesday after pleading guilty to the manslaughter of Zeljko "Steve" Mitrovic in January 2013 at the bikie's Weatherill Park workplace Dynamic Transport.
He also admitted causing grievous bodily harm with intent to Michael Bell - an office worker who was struck by one of the bullets.
The Basanovics were jailed in 2016 after a jury found the son guilty of manslaughter and the father guilty of murder.
But Michael Basanovic's murder conviction was quashed last year and a new trial ordered.
He later pleaded guilty to manslaughter on the basis of having used excessive self-defence.
He admitted to agreeing with his son to kill Mitrovic and going with him to the workplace where the bikie was shot dead during a heated argument.
The Crown accepted there was a reasonable possibility the older Basanovic believed such conduct was necessary to defend himself, but that it was not a reasonable response in the circumstances as he perceived them.
The Crown and defence agreed with Justice Richard Button's summary of the guilty plea starting with Michael Basanovic having been involved heavily in the "criminal milieu".
Arising from that, he had a fear of death which led him to form a criminal enterprise with his son to kill the person he was afraid of.
Mitrovic had been a full member of the Hells Angels since 2007, while Michael Basanovic was a member of the Bandidos from 1997 to 1999 and then the Hells Angels from 2009 to 2011.
In April 2011, Basanovic told a detective he no longer belonged to any outlaw motorcycle gang and his departure from the Hells Angels had not been voluntary.
He also said: "Things can only get worse from here. Because of them, my son cannot join the defence force."
"I have to protect my family. If they threaten my family again, then I have to do what I have to do," he said.
He also spoke about financial difficulties certain ex-members were having and about "patching over" from the Bandidos to the Hells Angels.
An expert, quoted in the statement of facts, said patching over could result in violence or fines or demands for compensation.
Basanovic will be sentenced on December 11.
His son was jailed for at least 11 years in 2016.