BRIDGEWATER, J.
¶ 1 Janice Hulscher appeals from the trial court's order modifying her spousal support award, arguing the spousal support provision is nonmodifiable by its terms. When parties include a nonmodifiable spousal maintenance provision in a separation contract, generally our courts may not modify spousal maintenance unless the provision was unfair when entered. We hold that parties need not enter a separate written instrument constituting their separation...
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