What is the test for a motion for a new trial based on newly discovered evidence?

"A motion for a new trial based on newly discovered evidence is not favored and a district court must exercise great caution ... and may grant the motion only in the most extraordinary circumstances." United States v. Diaz, 176 F.3d 52, 106 (2d Cir. 1999) (emphasis in original) (quotations and citations omitted). "Such relief should be granted only if the evidence is material to the verdict, could not with due diligence have been discovered before or during trial and is not cumulative." United States v. Sasso, 59 F.3d 341, 350 (2d Cir. 1995). To satisfy the materiality element where the government was unaware of the alleged perjury at trial -- and no claim is made here to the contrary -- a defendant must demonstrate that "but for the perjured testimony, [he] would most likely not have been convicted."

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