The rhetoric in a civil complaint is usually wrong on some points. He's not obliged to avoid hyperbole. The civil complaint is "notice" to the defendant, and has to state a claim that a court will recognize and enforce, if plaintiff can produce evidence of the relevant facts.
The number of rounds fired is totally irrelevant to his client's legal claim.
Silly me. When I see a legal document with a heading "Factual Background" I have a certain logical expectation, based on my knowledge of the English language. Of course, John Roberts should have disabused me of that, but, I guess I am a slow learner.