Exhibit 31 Placeholder — BofA Ca Unemployment (Dkt. 565.7)

What This Document Is

Per the Hoyle declaration (565.2), this is Exhibit 31 to BofA's motion to exclude Chloe N. East's opinions — "a true and correct copy of BANA's Remediation Plan, a document produced by BANA in this action Bates stamped BANA_EDD_MDL-00102554." The PDF on file is a placeholder cover sheet reading "PLACE HOLDER OF DOCUMENT SOUGHT TO BE SEALED IN ITS ENTIRETY," filed provisionally under seal pursuant to the Stipulated Protective Order.

Factual Summary

This is a sealing placeholder, but its identity is unusually significant: this is BofA's own Remediation Plan, connected to the CFPB/OCC Consent Order remediation process referenced elsewhere in this docket (the 569.x/571.x/591.x filings). The same declaration confirms this docket's Exhibit 28 is the CFPB Consent Order (dated July 14, 2022, filed at 565.4) and Exhibit 29 is the OCC Consent Order (dated July 14, 2022, filed at 565.5) — both NEAR-duplicate pointers: 565.4 points to the canonical payload at 324.75 (title on file: "2022-CFPB-0004-Bank of America N.A. - Consent Order"), and 565.5 points to the canonical payload at 566.5.

Key Facts

• Filed October 17, 2025 as Exhibit 31 to the Hoyle declaration (565.2) in support of BofA's motion to exclude East (565.0/565.1).
• Sealing status: filed provisionally under seal pursuant to the Stipulated Protective Order (ECF 82) — the archived PDF is a placeholder cover sheet only.
• Bates number: BANA_EDD_MDL-00102554 — identified by the declaration as "BANA's Remediation Plan," a single, specific internal document (not merely "a document produced by BANA," as with the other Bates exhibits in this docket).

Source Caveats

• Sealed placeholder: the PDF on file is a placeholder cover sheet with no underlying document content. This summary's identification is drawn entirely from the authenticating declaration, not from independent reading of the sealed exhibit.