In Garroutte v. State, 683 P.2d 262 (Alaska App. 1984) the Court held that a co-defendant's post-trial offer of exculpatory testimony did not constitute newly discovered evidence under Criminal Rule 33. The Court concluded that a co-defendant's "belated willingness to testify does not amount to new evidence," and suggested that the proposed exculpatory testimony was both unreliable and unlikely to produce an acquittal.