In Re Ferrebee (No. 90-22926-T, U.S.B.C. at Norfolk), 6 VLW 224, the United States Bankruptcy Court for the Eastern Division of Virginia held that the agreement between the debtor husband and his former wife in their separation agreement to hold one another harmless for the debts each had assumed is non-dischargeable in bankruptcy, because it is "in the nature of alimony." The Court found it clear that the parties intended this mutual hold-harmless obligation to be non-dischargeable, and their agreement can be said to have characterized the obligation as one of maintenance. Though these characterizations in agreements are not necessarily dispositive, this one certainly is.