In Ankeny v. Lockheed Missiles & Space Co. (1979) 88 Cal. App. 3d 531, Division Two of the First District Court of Appeal stated: "Plaintiff's complaint is also uncertain. In the civil complaint, he alleges conclusions of law such as 'tortiously caused' and 'conspired to tortiously cause' acts of an unspecified nature which somehow caused plaintiff to be passed over for promotion and deprived of stewardship in his union. It is settled law that a pleading must allege facts and not conclusions, and that material facts must be alleged directly and not by way of recital. Also, in pleading, the essential facts upon which a determination of the controversy depends should be stated with clearness and precision so that nothing is left to surmise. Those recitals, references to, or allegations of material facts which are left to surmise are subject to special demurrer for uncertainty. Such conclusionary allegations as are noted above, without facts to support them, are ambiguous." (Id. at p. 537.)