We review both the denial of a motion for a new trial and the denial of an evidentiary hearing in the motion-for-new-trial context for an abuse of discretion. State v. Green, 747 N.W.2d 912, 917 (Minn. 2008); State v. Hole, 400 N.W.2d 430, 434-35 (Minn.App. 1987) (holding that district court did not abuse its discretion by not permitting oral testimony at hearing on motion for new trial). "But we review de novo whether a defendant has been denied due process of law."

This court reviews the postconviction court's evidentiary and continuance rulings for an abuse of discretion. Johnson v. State, 697 N.W.2d 194, 198 (Minn. 2005); State v. Hole, 400 N.W.2d 430, 435 (Minn. App. 1987). As to the Carlsons' argument that the postconviction court erroneously limited their presentation of evidence, we note that the postconviction court provisionally received over 200 exhibits from the Carlsons at the postconviction evidentiary hearing.

Corroboration may even be established by an accused's limited admissions. For example, in State v. Hole, two accomplices testified that they were with the accused during a theft. 400 N.W.2d 430, 432 (Minn.App. 1987). The accused denied committing the crime but admitted being with the accomplices at the approximate time and place of the crime.

Ebert also cites Minn. R. Prof. Conduct 1.7, which prohibits an attorney from representing clients whose interests are "directly adverse" to each other. Ebert's attorney no longer represented Oldeen, and, although her interests in this criminal prosecution may have been at odds with Ebert's, Ebert's attorney was not representing her in this proceeding. Cf. State v. Hole, 400 N.W.2d 430, 434 (Minn.App. 1987) (concluding there was no prejudice from defense counsel's prior representation of co-defendant who had pleaded guilty and was not called as a defense witness). Thus, we conclude that Ebert has not shown an actual conflict of interest.

In addition, appellant's knowledge of L.J.'s reputation for untruthfulness or her chemical-use issues could have been easily confirmed and corroborated by appellant's and his counsel's due diligence between the January 1999 charging date and appellant's June 1999 waiver. Indeed, this information was eventually developed by the office of appellant's counsel, albeit in an unrelated matter. See, e.g., State v. Hole, 400 N.W.2d 430, 435 (Minn.App. 1987) (holding no abuse of discretion by denying new-trial motion where defendant's new evidence consists of witnesses who could have been discovered with due diligence prior to trial); Saiki v. State, 375 N.W.2d 547, 549-50 (Minn.App. 1985) (holding no abuse of discretion by denying new-trial motion where petitioner did not show that a witness who would have bolstered his defense could not have been discovered with due diligence prior to entering a guilty plea), review denied (Minn. Dec. 19, 1985).

Under these circumstances, the trial court properly considered the current medical condition of Bresnahan's former spouse in responding to her motion for amended findings and new trial. See Minn.R.Civ.P. 59.01 (permitting trial court to examine new evidence if presented in motion for amended findings and new trial); State v.Hole, 400 N.W.2d 430, 434 (Minn.App. 1987) (noting Minn.R.Civ.P. 59.01 allows trial court to amend findings of fact and make new findings upon motion for new trial). Thus, the trial court did not abuse its discretion in temporarily reserving jurisdiction over maintenance issues.