I, Youras Ziankovich, declare as follows:
- I am the Plaintiff in this action. I have personal knowledge of the facts stated herein and, if called as a witness, I could and would testify competently to them.
- I opened my Wise account on or about August 29, 2025.
- During the registration process, I was not required to agree to any Terms of Use or Customer Agreement as a condition of creating my account.
- I was not presented with any arbitration agreement or any provision stating that disputes would be resolved through arbitration.
- I did not click any button, check any box, or otherwise affirmatively indicate that I agreed to any arbitration provision.
- I was not presented with any terms in a clear and conspicuous manner that would reasonably inform me that I was agreeing to any contractual provisions by registering or using the service.
- At no time did I knowingly or voluntarily agree to waive my right to bring claims in court or to have disputes decided by a jury.
- I was able to create and use my Wise account without being required to accept any such terms.
- To the best of my knowledge, I was not provided with any version of the Customer Agreement dated September 12, 2025 at the time I created my account.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 27th day of March, 2026, in Baytown, Texas.
Youras Ziankovich