Defendant Wise US, Inc. (“Wise”), by and through undersigned counsel, respectfully moves this Court to enter an order, pursuant to the Federal Arbitration Act (“FAA”), 9 U.S.C. §§ 1 et seq., compelling Plaintiff Youras Ziankovich’s (“Plaintiff”) claims against Wise to arbitration and staying these proceedings pending resolution in arbitration. Alternatively, Wise respectfully moves this Court to enter an order, pursuant to Fed. R. Civ. P. 12(b)(6), dismissing all of Plaintiff’s claims against Wise.
In support of this Motion, Wise hereby adopts and incorporates the memorandum of law and exhibits filed contemporaneously herewith.
WHEREFORE, Wise respectfully requests that this Court compel Plaintiff’s claims against Wise to arbitration and stay these proceedings pending resolution in arbitration.
Alternatively, Wise respectfully requests that this Court dismiss Plaintiff’s claims against Wise for failure to state a claim upon which relief can be granted.
1 Pursuant to LR 7.1(D), counsel for Wise conferred with Plaintiff on March 10, 2026, via email prior to filing this Motion to ascertain whether an agreement could be reached regarding the relief sought herein. Plaintiff responded to this outreach, but an agreement could not be reached. Thus, Wise anticipates that the Motion will be opposed.
Respectfully submitted this 23rd day of March, 2026.
/s/ Reid S. Manley
Reid S. Manley
State of Texas Bar No. 24047520
BURR & FORMAN, LLP
420 North 20th Street, Suite 3400
Birmingham, Alabama 35203
Telephone: (205) 251-3000
Facsimile: (205) 458-5100
rmanley@burr.com
Attorney for Defendant Wise US, Inc.