(a) When an attorney disputes the existence of an agreement or stipulation,
the agreement is unenforceable unless:
(1) it is in writing and signed by an attorney of record for the party against
whom enforcement is sought;
(2) it is in an electronic communication sent by an attorney of record for
the party against whom enforcement is sought; or
(3) its existence is supported by a clerk’s minutes or a court reporter’s
record.
(b) In open court, an agreement or stipulation made by any attorney of
record for a party is enforceable against that party.