Zamora Alvarez v. Upper Restoration, Inc., and Matthew Lee, individually.; Index No.:25-6792

New Action filed in the United States District Court Eastern District of New York

On December 9, 2025, Plaintiff Zamora Alvarez, by and through his attorneys, Borrelli & Associates, P.L.L.C., as and for his Complaint against Upper Restoration, Inc., and Matthew Lee, individually, (together as “Defendants”), alleges upon knowledge as to himself and his own actions, and upon information and belief as to all other matter, as follows:

Plaintiff worked for Defendants – – a New York corporation that operates a Nassau County-based construction business and the corporation owner and day-to-day overseers – – as a non- managerial laborer, performing general construction work at various commercial and residential jobsites throughout New York state, from in or around March 2025 until September 10, 2025. As described below, throughout Plaintiff’s employment, Defendants willfully failed to pay Plaintiff the overtime wages lawfully due to him being under Fair Labor Standards Act and the New York Labor Law(“NYLL”). Specifically, throughout his employment, Defendants routinely required Plaintiff to work, and Plaintiff did work, beyond forty hours in a workweek, yet in exchange, Defendants paid Plaintiff at a flat hourly rate, which did not include overtime premiums at the statutorily-required rate of one and one-half times his regular rate of pay for all hours that he worked in excess of forty in a week. Defendants further violated the NYLL by failing to furnish Plaintiff with any wage statement on each payday or with any wage notice at his time of hire, let alone an accurate one. Defendants paid and treated all of their non- managerial laborers in the same manner.

If any individual is or has previously been an employee of the Defendants named in the lawsuit and/or has information that may be relevant to this case, please contact Borrelli & Associates, P.L.L.C. as soon as possible through one of our websites, www.employmentlawyernewyork.com or www.516abogado.com, or any of our phone numbers: (516) 248–5550, (516) ABOGADO, or (212) 679–5000.