EXHIBIT I - petrobrassecuritieslitigation.com

1 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.

2 ( PAI ) (collectively, the Petrobras Defendants ) and BB Securities Ltd., Citigroup Global Markets Inc., Morgan Securities LLC, Itau BBA USA Securities, Inc., Morgan Stanley & Co. LLC, HSBC Securities (USA) Inc., Mitsubishi UFJ Securities (USA), Inc. (n/k/a MUFG Securities Americas Inc.), Merrill Lynch, Pierce, Fenner & Smith Incorporated, Standard Chartered Bank, Bank of China (Hong Kong) Limited, Banco Bradesco BBI , Banca IMI and Scotia Capital (USA) Inc. (collectively, the Underwriter Defendants ) by and through their respective counsel in the above-captioned consolidated class action (the Action ). Case 1:14-cv-09662-JSR Document 767-1 Filed 02/01/18 Page 2 of 66 2 Almir Guilherme Barbassa, Jose Carlos Cosenza, Paulo Roberto Costa, Renato de Souza Duque, Guillherme de Oliveira Estrella, Maria das Graca Silva Foster, Jose Miranda Formigli Filho, Jos Sergio Gabrielli, Silvio Sinedino Pinheiro, Daniel Lima de Oliveira, Jos Raimundo Brand o Pereira, S rvio T lio da Rosa Tinoco, Paulo Jose Alves, Gustavo Tardin Barbosa, Alexandre Quint o Fernandes, Marcos Antonio Zacarias, Cornelis Franciscus Jozef Looman, and Theodore M.

3 Helms shall collectively be referred to in this Stipulation as the Individual Defendants. The Petrobras Defendants, the Underwriter Defendants, the Individual Defendants, Josue Christiano Gomes da Silva, Mari ngela Monteiro Tizatto, Banco Votorantim Nassau Branch, Santander Investment Securities Inc., Petrobras International Finance Company, PricewaterhouseCoopers Auditores Independentes ( PwC Brazil ), and any other Person that is or has been at any time a defendant in this Action, shall collectively be referred to in this Stipulation as the Defendants. Class Representatives, the settlement Class Members, the Petrobras Defendants, and the Underwriter Defendants shall collectively be referred to in this Stipulation as the Settling Parties. A. WHEREAS, beginning in December 2014, several putative securities class actions were filed on behalf of investors against the Defendants or certain of them. The lawsuits alleged violations of Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the Exchange Act ), 15 78j(b), 78t(a), and Securities and Exchange Commission ( SEC ) Rule 10b-5 promulgated thereunder, as well as Sections 11, 12(a)(2), and 15 of the Securities Act of 1933 (the Securities Act ), 15 77k, 77l, 77o.

4 By Order dated February 17, 2015, the District Court consolidated these actions, and by Order dated March 4, 2015, the District Case 1:14-cv-09662-JSR Document 767-1 Filed 02/01/18 Page 3 of 66 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 78u-4 and 15 77z-1 (the PSLRA ). B. WHEREAS, on March 27, 2015, USS filed a Consolidated Amended Complaint ( CAC ) against certain of the Defendants for violations of Sections 10(b) and 20(a) of the Exchange Act and Sections 11, 12(a)(2), and 15 of the Securities Act , which named additional plaintiffs, including Hawaii. C. WHEREAS, on April 17, 2015, Petrobras, PGF, and the Underwriter Defendants filed a motion to dismiss the CAC, and on July 10, 2015, the District Court granted in part and denied in part the motion to dismiss the CAC.

5 Among other decisions, the District Court dismissed claims relating to certain debt securities issued in 2012 under the Securities Act as time barred by the applicable statute of repose, and ruled claims relating to securities purchased on the Brazilian stock exchange (the BOVESPA ) must be arbitrated, as established in Petrobras s bylaws. The District Court also ruled that claims under Section 11 of the Securities Act were dismissed to the extent they were based on purchases of the Petrobras notes issued in 2013 made after August 11, 2014. The District Court rejected other arguments presented in the motion to dismiss the CAC, and, as a result, the case continued with respect to those claims. D. WHEREAS, on July 16, 2015, Lead Plaintiff filed its Consolidated Second Amended Class Action Complaint ( SAC ), and on September 1, 2015, Lead Plaintiff filed its Consolidated Third Amended Class Action Complaint ( TAC ), both alleging substantially similar claims against certain of the Defendants as the CAC and naming an additional Defendant.

6 The TAC added North Carolina as an additional plaintiff, and named additional defendants Paulo Roberto Costa, Jose Carlos Cosenza, Renato de Souza Duque, Guillherme de Oliveira Estrella, Case 1:14-cv-09662-JSR Document 767-1 Filed 02/01/18 Page 4 of 66 4 Jose Miranda Formigli Filho and Petrobras America Inc. In an order dated December 20, 2015, the District Court dismissed with prejudice the claims of Class Representatives under Section 11 of the Securities Act to the extent they were based on purchases of Petrobras notes issued in 2014 made after May 15, 2015. E. WHEREAS, on October 15, 2015, Class Representatives filed a motion for class certification, appointment of class representatives, and appointment of class counsel, which the Petrobras Defendants and the Underwriter Defendants opposed on November 6, 2015, and which was fully briefed by November 23, 2015. F. WHEREAS, on November 30, 2015, Plaintiffs filed their Consolidated Fourth Amended Class Action Complaint ( FAC ).

7 On December 20, 2015, the District Court granted in part and denied in part Defendant s motion to dismiss the FAC. On December 23, 2015, Defendant PwC Brazil moved to dismiss the claims against it in the FAC. By Order dated February 19, 2016, the District Court granted in part and denied in part PwC Brazil s motion to dismiss. PwC Brazil s motion was granted with respect to the Section 10(b) claim, but denied with respect to the Section 11 claim. By Order entered May 5, 2016, the District Court denied USS s request for leave to amend the FAC to assert a new Section 10(b) claim against PwC Brazil. G. WHEREAS, on February 2, 2016, the District Court issued its Opinion and Order granting Plaintiffs motion for class certification, appointment of class representatives, and appointment of class counsel ( Class Certification Order ). The District Court certified a Securities Act class and an Exchange Act class, appointed USS as Class Representative for the Exchange Act class, and appointed North Carolina and Hawaii as Class Representatives for the Securities Act class.

8 The District Court also appointed Pomerantz LLP as Class Counsel. Case 1:14-cv-09662-JSR Document 767-1 Filed 02/01/18 Page 5 of 66 5 H. WHEREAS, on February 16, 2016, the Petrobras Defendants and the Underwriter Defendants requested leave to appeal the Class Certification Order to the United States Court of Appeals for the Second Circuit (the Second Circuit ). On June 15, 2016, the Second Circuit granted the petition for leave to appeal the Class Certification order pursuant to Fed. R. Civ. P. 23(f). I. WHEREAS, on June 27, 2016 and June 29, 2016, the Petrobras Defendants and Plaintiffs each moved for partial summary judgment as to certain claims asserted by Plaintiffs and, on June 27, 2016, the Underwriter Defendants and certain of the Individual Defendants moved for summary judgment as to all claims asserted by the Plaintiffs. J. WHEREAS, the District Court had set a trial date of September 19, 2016, but on June 28, 2016, before the motions for partial summary judgment were fully briefed, the Petrobras Defendants and Underwriter Defendants moved for a stay of the Action and all District Court proceedings consolidated with the Action until issuance of a mandate by the Second Circuit, pending consideration of Defendants appeal of the Class Certification Order pursuant to Fed.

9 R. Civ. P. 23(f), and on August 2, 2016, the Second Circuit granted that motion. K. WHEREAS, on July 7, 2017, the Second Circuit entered an order, vacating the class certification order, and reversing in part and affirming in part, and remanding to the District Court for further proceedings. Among other things, the Second Circuit vacated the District Court s Order granting class certification and rejected the argument that the class certification order defined classes that were not ascertainable and determined that the classes were ascertainable. The Second Circuit remanded the case for the District Court to consider whether the proposed classes satisfied the predominance requirement. Pursuant to Federal Rule of Case 1:14-cv-09662-JSR Document 767-1 Filed 02/01/18 Page 6 of 66 6 Appellate Procedure 41, the mandate was to issue in 21 days absent further order of the Second Circuit. L. WHEREAS, on July 21, 2017, before the mandate was to issue, the Petrobras Defendants and the Underwriter Defendants filed a Petition for Panel Rehearing and Rehearing en banc, staying issuance of the mandate, which the Second Circuit denied on August 24, 2017.

10 On August 30, 2017, within the period permitted by the Federal Rules of Appellate Procedure, the Petrobras Defendants and Underwriter Defendants filed an unopposed motion to stay the issuance of the Second Circuit s mandate pending the filing of a petition for a writ of certiorari to the United States Supreme Court. M. WHEREAS, on November 1, 2017, the Petrobras Defendants and the Underwriter Defendants filed at the United States Supreme Court a petition for a writ of certiorari seeking review of the Second Circuit s decision affirming, in part, the Class Certification Order on issues: (1) regarding the proof required to establish a presumption of reliance in securities fraud cases under Basic Inc. v. Levinson, 485 224 (1988) and Halliburton Co. v. Erica P. John Fund, Inc., 134 S. Ct. 2398 (2014); and (2) whether class membership is required to be ascertainable through administratively feasible means under Rule 23 of the Federal Rules of Civil Procedure (the Petition ).