. .” Cox v. Global Tool Supply LLC, 629 F.Supp.3d 963, 972 (D. Ariz. 2022) (citation omitted). Crediting as true that Plaintiff suffered adverse physical reactions to the excessive pesticide treatments, the factual allegations pleaded in the Second Amended Complaint do not suggest that Defendant intended to inflict harm or that it acted with reckless disregard.

California courts have stated that “[t]he purpose behind the alter ego doctrine is to prevent defendants who are the alter egos of a sham corporation from escaping personal liability for its debts. Cox v. Global Tool Supply LLC, 629 F.Supp.3d 963, 973 (D. Ariz. 2022): Under Arizona alter ego theory that (1) unity of control and (2) observance of the corporate form would sanction a fraud or promote injustice must be shown. Same factors as in GeoSolutions and In re Packaged Seafood.

See Cox v. Glob. Tool Supply LLC, 629 F.Supp.3d 963, 973 (D. Ariz. 2022) (plaintiff alleging anxiety, depression, weight fluctuations, and loss of trust failed to show severe emotional distress as a matter of law); see also Bodett v. CoxCom, Inc., 366 F.3d 736, 747-48 (9th Cir. 2004) (“false accusations alone not enough to constitute an intentional infliction of emotional distress” under Arizona law).

Albano v. Shea Homes Ltd. P 'ship, 634 F.3d 524, 528 (9th Cir. 2011) (cleaned up). See also Cox v. Glob. Tool Supply LLC, 2022 WL 4356915, *4 (D. Ariz. 2022) (“Arizona's equitable tolling rules apply to ACRA claims.”); Reed v. Pioneer Landscaping Materials Inc., 2010 WL 11515553, *2 (D. Ariz. 2010) (“Where a district court applies or borrows a state statute of limitations, it is also required to apply the state's equitable exceptions, to the extent these are consistent with federal law.