1A permanent injunction may be granted to restrain persons from relying on a death certificate obtained by misrepresenting the deceased's marital status and from asserting the validity of a revoked will, where such conduct threatens the lawful administration of an estate and damages are not an adequate remedy.
2Where defendants have strenuously avoided service and declined to participate in proceedings, the court may draw adverse inferences that they are unable to produce evidence of compliance with prior court orders and that any evidence they might adduce would not assist their case.
3Failure to accept a Calderbank offer will be found unreasonable where the offeree's conduct necessitated urgent proceedings, the offeree attempted to avoid service, and the offeree continued to act in flagrant contravention of existing court orders.