If both the diphenydramine and ondansetron were given, who's to say that it was the ondansetron at all? In fact, if they didn't re-initiate the ondansetron and reproduce the tremor, they can't say that it was EITHER drug that was causing it. It could be something else entirely. BUT... there have been a few documented cases.
From micromedex:
3.3.9.A.2 Extrapyramidal sign
a) Unlike metoclopramide, ondansetron has only very rarely been associated with acute DYSTONIC REACTIONS, AKATHISIA, or other extrapyramidal reactions. Three reports that are consistent with, but not diagnostic for extrapyramidal reactions have been reported (Prod Info Zofran(R), 2001a). Case reports have described extrapyramidal reactions in a few patients receiving ondansetron (Garcia-del-Muro & Ferrer, 1993, Halperin & Murphy, 1992)(Dobrow et al, 1991). The relative lack of extrapyramidal effects with ondansetron confirms the absence of dopamine antagonist activity (Marty et al, 1990c; Marty, 1989c).
b) ACUTE CHOREA lasting 5 days occurred in a 34-year-old woman who received intravenous (IV) ONDANSETRON 4 mg for nausea after a cesarean section. The patient had no relevant medical history; she was not taking any medications and did not use drugs. After the ondansetron injection, she felt a sensation in her feet, which moved up her body. In the recovery room, she started to experience involuntary movements, somewhat similar to intention tremor and shivering. Involuntary movements continued and occurred in her trunk and lower limbs as the motor block wore off. Fifteen episodes lasting 20 to 150 seconds per episode were documented by hospital staff over a 6-hour period. The episodes were characterized by paroxysmal involuntary choreiform movements involving the neck and all 4 limbs (primarily proximal muscles). She was given a loading dose of IV benztropine 2 mg, followed by 1-mg doses orally 3 times a day. As of day 5, the episodes ceased, and the patient experienced full resolution (Duncan et al, 2001).
c) Another case report describes a 71-year-old male who experienced an extrapyramidal reaction (ie, twitching and tremors of the neck, shoulders, and head) following a second 30-milligram dose of ondansetron. After discontinuation of the drug, the symptoms quickly disappeared (Mathews & Tancil, 1996).