Exhibit 31 Placeholder — BofA Ca Unemployment (Dkt. 566.7)

What This Document Is

Per the Hoyle declaration (566.2), this is Exhibit 31 to BofA's motion to exclude David I. Levine'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. This is the same Remediation Plan document already summarized once for its parallel filing in the Chloe East exclusion motion (565.7).

Factual Summary

This is a sealing placeholder — a re-filing of the identical Bates-numbered document (BANA_EDD_MDL-00102554) already sealed at 565.7 for the East exclusion motion. This declaration confirms the same appendix structure recurs across the docket's coordinated five-expert Daubert wave: Exhibit 28 (CFPB Consent Order, July 14, 2022, filed here at 566.4, a NEAR-duplicate pointer) and Exhibit 29 (OCC Consent Order, July 14, 2022, filed here at 566.5) are filed alongside this Remediation Plan in each of the five coordinated exclusion motions (Cloninger, Minnucci, East, Levine — Regan's set uses a different exhibit numbering, see 567.x).

Key Facts

• Filed October 17, 2025 as Exhibit 31 to the Hoyle declaration (566.2) in support of BofA's motion to exclude Levine (566.0/566.1).
• 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 — identical to the Remediation Plan exhibit already sealed at 565.7 in the East motion; confirms BofA re-filed the same core exhibit set (Consent Orders + Remediation Plan) across at least four of its five coordinated Daubert motions.

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.