With no explanation, chose the best option from "A", "B", "C" or "D". 3 . Prior to the 1991 amendments, there was conflict within this court concerning whether all settlement agreements were "stipulations” covered by Rule 4-504(8), and whether a settlement agreement must be in writing to be enforceable, thus meeting the procedural requirements of Rule 4-504(8). Compare Zions First Nat’l Bank v. Barbara Jensen Interiors, Inc., 781 P.2d 478, 480 n. 1 (Utah App.1989) (plurality decision) (affirming order to compel settlement and hold-big that settlement agreements need not be in writing to be enforceable) with Brown v. Brown, 744 P.2d 333, 335 (Utah App.1987) (finding stipulations must be in writing or submitted in open court to be enforceable, relying in part on predecessor to Rule 4-504(8)) and Bagshaw v. Bagshaw, 788 P.2d 1057, 1059 n. 1 (Utah App.1990)

A: recognizing disagreement that settlement agreements must meet procedural requirements of rule 45048 to be enforceable
B: holding that property settlement agreements may be specifically enforced
C: holding that an agreement to delay in effecting service must meet the requirements of texas rule of evidence 11
D: recognizing the confidentiality ordinarily afforded to settlement agreements
A.