No. It is easy to create a raw 3D-plane file with fixed depth values, but anyway, as far as I know, there is currently no way to embed it in the MVC stream before remuxing it. You would need a MVC encoder that supports the 3D-planes, and currently, the only free MVC encoder (the Intel) can't do that. In other words, if you re-encode a 3D BD (as AVC+MVC), the depth of the subtitles is irremediably lost. It's one of the big advantages of the SBS or T&B formats: you can keep the depth of the subtitles by including or hardcoding the 3D subtitle stream.
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