How to create a new cell in a layout nested within another cell?

I am trying to use Python scripting to create some cells that will themselves be nested within other cells.

So far I can only find commands to create a new cell as a top-level cell, not a nested one. e.g.
will create a new, top-level cell named "NewCell"

Now let's say I've created another cell:

How would I get OtherCell to be nested under NewCell in the cell hierarchy?


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