The mother of a man who gunned down gangland figure Gavin Preston has called her killer son respectful, caring and kind as prosecutors pushed for him to be jailed for life.
Jaeden Tito's mother Levi took the unusual step of reading her character reference aloud in the Victorian Supreme Court on Friday as her son faced a pre-sentence hearing.
Tito, 25, and his co-offender Rabii Zahabe, 26, were in May found guilty of murdering Preston, 50, in Melbourne's northwest on September 9, 2023.
Footage played to the jury showed Preston and his friend Abbas Maghnie seated outside Sweet Lulus cafe in Keilor when two men dressed in black jumped out of a car and fired shots.
Preston was fatally struck while Mr Maghnie was also hit but survived, with Tito and Zahabe also convicted of his attempted murder.
With Preston's loved ones sitting close by, Mrs Tito described her son as someone with a kind and caring nature who brought joy into all of their lives.
"Our family is no longer complete and the absence of our son is felt constantly," she read aloud while under oath.
"We miss him deeply and we long for the day that he can come home with us, although we know that day is not near."
Mrs Tito admitted to the judge she had used ChatGPT to craft her character reference but said she still meant every word.
Senior crown prosecutor Kristie Churchill KC told the court no victim impact statements would be submitted, although Preston was still dearly loved and missed by his family.
She argued this case fell into the worst category of murder, given it was a public execution in a busy suburban cafe.
Ms Churchill said the only appropriate sentence was life in prison, highlighting how the hit was sophisticated and extensively planned, with members of the public also put in danger.
Tito's barrister Daniel Sala argued against a life sentence, telling the judge it was instead open for him to impose a jail term of up to 50 years.
"The fact it's not previously done is not a restriction on Your Honour," Mr Sala said.
"Your Honour should consider a sentence within that range as more than appropriate."
He argued Tito was not the one who planned the murder and instead was a component of a much larger machine.
Zahabe's barrister Paul Smallwood also argued against a life jail term, pointing to the fact his client was a young man who had been isolated in custody since his arrest.
Zahabe had previously experienced drug abuse problems and anxiety and depression, which could make his time in custody more difficult, the barrister said.
Justice Michael O'Connell adjourned the hearing to allow the parties to provide more material about the two gunmen's future conditions in custody.
Tito and Zahabe were remanded to their next Supreme Court appearance.
