Garcia

facts sufficient to support a finding that P & Z Group can be held liable, whether as her 26 employer, an alter ego of Zavala, or an alter ego of P & Z Foods. Although, in her 27 Mallison in Supp. of Pl.’s Mot. for Default J. (“Mallison Suppl. Decl.”) ¶ 2) and exhibits (see id. Exs. 1-11) with regard to the third of the above-referenced theories of liability, the allegations in Garcia’s operative complaint, namely, the Second Amended Complaint, are “too conclusory” to state a claim for alter ego liability, see Sandoval v. Ali, 34 F. Supp. 3d 1031, 1040 (N.D. Cal. 2014) (noting, to state a claim for alter ego liability, “plaintiff must allege specifically both of the elements” thereof, “as well as facts supporting each” (internal quotation and citation omitted)), and facts that are “not established by the pleadings” and claims that “are not well-pleaded . . . cannot support [a default] judgment,” see Danning v. Lavine, 572 F.2d 1386, 1388 (9th Cir. 1978); see also Alan Neuman Prods., Inc. v. Albright, 862 F.2d 1388, 1392-93 (9th Cir. 1988) (finding “error to award a default judgment” where complaint “fail[ed] properly to allege a…