In a striking legal battle, a former employee has taken action against his previous employers for allegedly violating labor laws and withholding wages. On November 17, 2025, Raul Gustavo Loja Ayavaca filed a complaint in the United States District Court for the Southern District of New York against Stone Works America Corp, Eurasia Stone and Tile Import Corporation, and Mehmet Arli. The lawsuit accuses these defendants of breaching both federal and state labor laws by failing to compensate him for his work.
The case centers around allegations that the defendants violated the Fair Labor Standards Act (FLSA) and New York Labor Law (NYLL) by not paying Ayavaca for overtime hours worked beyond forty per week. According to the complaint, Ayavaca was employed as a tile installer from October or November 2022 until June 6, 2025. During this period, he claims he was paid a flat daily rate without receiving any overtime pay despite regularly working over forty hours weekly. Moreover, he alleges that from May through June 6, 2025, he received no payment at all for his services.
Ayavaca’s accusations extend beyond unpaid wages; he also contends that the defendants failed to provide legally required wage statements and new-hire notices as stipulated under NYLL § 195(1). Furthermore, Ayavaca highlights that as a manual worker—engaged in physically demanding tasks like carrying tiles and demolition—he should have been compensated on a weekly basis rather than monthly. The plaintiff also points out discrepancies in uniform maintenance practices, claiming he had to clean his work attire at personal expense due to insufficient provisions from his employers.
The complaint seeks various forms of relief from the court: compensation for unpaid wages including overtime; liquidated damages equal to unpaid wages; statutory penalties; spread-of-hours premiums; uniform-maintenance allowances; reasonable attorneys’ fees; pre-judgment and post-judgment interest; along with any other relief deemed appropriate by the court. Through this legal action, Ayavaca aims to hold his former employers accountable for their alleged violations of labor laws.
Representing Raul Gustavo Loja Ayavaca is attorney Mohammed Gangat from the Law Office of Mohammed Gangat. The case is presided over by judges within the Southern District of New York under Case ID 1:25-cv-09577.
Source: 125cv09577_Raul_Gustavo_v_Stone_Worksr_Complaint_Southern_District_of_New_York.pdf
