The MLK quote preamble and Black History Month stuff irritated me, frankly. Neither has a place in a complaint, at least one is inflammatory, and there are several federal judges I know (and you probably know some) that would reprimand (orally not officially) and demand a refiling. But it is, as you say, a very savvy pleading. On top of it, the timing indicates to me that there wasn't a whole lot of negotiation before drafting/filing. Like none.