This section is from the book "The Law Of Contracts", by William Herbert Page. Also available from Amazon: Commercial Contracts: A Practical Guide to Deals, Contracts, Agreements and Promises.
Contracts of record other those enumerated are naturally rare. They are not, however, entirely unknown. It has been held that a contract made between the parties to pending litigation in open court, and entered on the journal as a proceeding in the cause, "has all the force and effect of a contract of record."1 Such a contract has been held not to be within the operation of the statute of frauds.2
5 Black. Com. II. 160.
1 Huston v. Ry., 21 0. S. 235.
2 See Sec. 737.