In Adams v. Adams, 29 Cal. 2d 621, 177 P.2d 265, 267 (Cal. 1947), the Supreme Court of California recognized that a husband and wife, upon separation, may agree to provide for support and maintenance in a variety of ways, which generally fall into three categories. 177 P.2d at 267. The first includes agreements in which the support provisions are in the nature of alimony, whether in lump sum or periodic payments, and are "separable from the provisions that divide the property." Id. "If presented to a court in an action for divorce the court has the power to modify the provisions for alimony before or, if the provisions are incorporated in the decree, after judgment in accord with its power over alimony generally." Id. The second category includes contracts in which the support provisions are not in the nature of alimony but are part of the parties' division of property, including agreements that provide solely for the payment of periodic or lump sums "in lieu of community property." Id. Such contracts must be treated like other property settlement agreements dealing solely with divisions of property, meaning that absent fraud or violation of the parties' confidential relationship, the payments cannot be modified after the decree without the consent of the parties. Id. The Court held that marital property settlement agreements can be separated into three categories based on the level of connection between property distribution provisions and provisions for spousal or child support. The first type of marital property settlement agreement includes agreements where property distribution provisions are entirely separate from support provisions. Id. When the support and distribution provisions are entirely separate, the trial court retains authority to modify the support provisions but not the property distribution provisions. Id. In the second type of agreement, "the support and maintenance provisions are not in the nature of alimony but are part of the division of property." Id. When support provisions are part of the property distribution, the trial court may not modify the terms of the agreement without the consent of the parties unless there was fraud in the creation of the agreement. Id. The third category of agreement involves agreements where one spouse waives entitlement to support in return for a more favorable property distribution. Id. at 268. Like agreements that fall within the second category, a court may not modify the terms of this third type of agreement since to do so would "change basically the agreement of the parties as to the division of their property." Id.