He attended the Terang racecourse twice on race days, watched the operations surround the cash being collected at the track and followed the security guard responsible for carrying the cash in order to learn his movements.

On December 31, Driver met with an undercover officer at Warrnambool’s Rafferty’s Tavern when he discussed committing an armed robbery at the Terang racecourse on New Year’s Day. These meetings were recorded.

Driver said he wanted to target the security responsible for transporting the day’s takings from the racetrack.

He told the officer he had followed the guard twice to see how he operated and he was concerned about the guard as he seemed to be able to defend himself.

In preparation, Driver accompanied the covert operative in his vehicle to do a dry run over the target location.

Driver stated that to do the job he wanted a decent weapon such as a sawn-off shotgun. He stated his firearm was too small and conspicuous as it was old.

Prior to going to the Terang racecourse, Driver discussed committing an armed robbery on a TAB in Warrnambool.

Driver showed the covert operative the location and discussed committing an the offence where he would steal cash from the safe and tie up staff. He also discussed CCTV in the area and removing keys and mobile telephones from those present at the TAB to aid in the getaway.

Driver also discussed targeting the Commonwealth Bank by posing as a window cleaner. He told the covert operative he believed they could get at least $100,000, and maybe up to $300,000 or $400,000. He also discussed tying up the staff members and waiting while the time delay on the safe opened.

In discussing the planned armed robbery at the Terang racecourse he said: “the only other thing is I reckon — come out of the bushes with me, with me cannon and just get him, get him facing me and then you, you might have something like a f… bat or something, just give him, give him a touch up, and put him down? I think, I think you’re gonna have to.”

Driver directed the covert operative to drive to the Terang racecourse, en route he pointed out other locations that he was considering as targets including the Flying Horse brewery, The Good Guys and McDonald’s.

The accused also told the covert operative what to wear, detailing that he should wear clothing with no brand names that was plain and nothing that could be distinguished.

“You’re asking too many questions, don’t worry if f… someone needs to be shot. It’ll be done, it’ll be f... done, don’t worry,” Driver said.

The robbery at the racecourse was called off as Driver told the undercover operative he was ill.