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Mr Burgess, who had one leg, was then Tasered by Police constable Rachel Comotto, police body-worn camera footage shown to jurors appeared to show.
PC Smith, 51, denies two counts of assault by using Pava spray and a baton, and PC Comotto denies one charge of assault by discharging her Taser.
"It ought to have been obvious by the fact he had one leg that this was a man who wasn't going to be mobile.