Only attorneys who are authorized to enter into binding stipulations may appear at pretrial conferences, pursuant to 22 NYCRR 202.26[e] and 22 NYCRR 202.12[b]. Therefore, an attorney's presence at a pretrial conferences is an implied representation by the attorney's client to the other side that the attorney has authority to bind the client to a stipulation. A stipulation made by the attorney may bind a client even where it exceeds the attorney's actual authority if the attorney had apparent authority to enter into the stipulation.
Chae Shin Oh v. Jeannot, NY Slip Op 02446 (2d Dep't April 11, 2018)
Here is the decision.