Transcription of EXHIBIT I - petrobrassecuritieslitigation.com
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EXHIBIT I - petrobrassecuritieslitigation.com
EXHIBIT I Case 1:14-cv-09662-JSR Document 767-1 Filed 02/01/18 Page 1 of 66 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ) No. 14-cv-9662 (JSR) ) IN RE PETROBRAS securities ) LITIGATION ) ) ECF CASE ) ) STIPULATION OF SETTLEMENT AND RELEASE This Stipulation of Settlement and Release, dated February 1, 2018 ( Stipulation ) is submitted pursuant to Fed. R. Civ. P. 23 and Fed. R. Evid. 408. Subject to the District Court s approval, this Stipulation is entered into by and between (i) the District Court-appointed Class Representatives Universities Superannuation Scheme Limited (acting as sole corporate trustee of Universities Superannuation Scheme) ( USS ), North Carolina Department of State Treasurer ( North Carolina ) and Employees Retirement System of the State of Hawaii ( Hawaii ) (collectively, Class Representatives or Plaintiffs ), individually and on behalf of each Settlement Class Member (as defined herein) and (ii) Petr leo Brasileiro Petrobras ( Petrobras ), Petrobras Global Finance ( PGF ), and Petrobras America Inc.
3 Court appointed USS as Lead Plaintiff, and appointed Pomerantz LLP as Class Counsel for the Settlement Class, pursuant to the Private Securities Litigation Reform Act of 1995, 15 U.S.C.
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