What is the test for a motion for a new trial based on evidence that was not produced at trial?

In Wernet's motion for a new trial, she requested that the court consider additional evidence that was not produced at trial. But additional evidence may only be considered if the party making the motion shows the evidence could not with reasonable diligence have been discovered and produced at trial. (Code Civ. Proc. 657, subd. 4.) Because of the possibility that the moving party may have been guilty of neglect, a motion based on such evidence is viewed with "suspicion and disfavor." (Horowitz v. Noble (1978) 79 Cal.App.3d 120, 138.) Thus, a strong showing is necessary. Here

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