I skimmed the complaint, and it certainly needs some tweaking. You've written it like a story, and included case law. However, you don't make legal arguments in a complaint, and you don't need the kind of detail that you state. You can see a sample complaint here: CLICK HERE
. It's from a different court, but complaints are the same in all courts. It is a good example. The complaint merely states necessary facts that support a particular cause of action.
You also asked:
Q: how do I later change JOHN DOE's to actual names if/when I learn them through discovery ?
A: You can request leave of court to amend the complaint.
Q: Do I file an amended Complaint ? If so, how many times can I amend?
A: You can amend it as many times as the court will allow it. If you request leave of court to amend the complaint merely for the purpose of changing a name from John Doe to the party's actual name, then the court would almost certainly grant leave of court for that purpose as many times as is necessary.
Q: And would I have to serve those on all parties again ?
A: Yes, you would have to serve all parties. However, once a party has been served once, documents can be subsequently served by regular mail.
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