HOWARD, Circuit Judge.
Under Massachusetts domestic relations law, a married couple may obtain the benefits of a "no fault" divorce by averring that "an irretrievable breakdown of the marriage exists" and persuading a probate court judge to approve a notarized separation agreement setting forth the terms on which the marriage is to be dissolved. Mass. Gen. Laws ch. 208, § 1A. In such circumstances, the separation agreement "shall either be incorporated and merged...
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