As a bail application for Moran was again adjourned this morning, Defence lawyer Jim Stavris told Victoria's Supreme Court that his client required three operations and was expected to be treated in the public health system within the next 90 days.

Mr Stavris told Justice Simon Whelan Moran required an arthroscope on her knee; an X-ray-guided cortisone injection to her hip; and she had a "displaced cheekbone" which required treatment following an incident in prison last October.

Moran and co-accused Suzanne Kane, Geoffrey Armour and Michael Farrugia have been committed to stand trial over the murder of her brother-in-law, Des 'Tuppence' Moran, following an alleged squabble over money.

Mr Moran was shot dead at his favourite Ascot Vale coffee spot on June 15 last year.

Moran was charged on the day of his death with being an accessory to murder. Her charge was later upgraded to murder.

"Since being in custody, for whatever reason, she's not mobile to a position where she is in a wheelchair and she's deteriorated since being in custody," Mr Stavris said.

He added it was impossible to say whether she would have received the required treatment and be rehabilitated to a point where she could effectively participate in the trial, set to begin early next year.

Mr Stavris requested Moran's bail application be adjourned to a date to be fixed so further assessments could be made.

Justice Whelan granted the adjournment.

Moran, who watched this morning's hearing from her motorised wheelchair at the back of the court, has twice been refused bail in the Magistrates Court.

She has also adjourned bail applications several times in the Supreme Court.

The 65-year-old and her co-accused will re-appear for a pre-trial hearing before Justice Lex Lasry on November 22.