In pleading. The statement of matters of fact directly (excluding the necessity of Inference or argument to arrive at the meaning) and in such appropriate terms, so arranged, as to be comprehensible by a person of common or ordinary understanding. See Merrill v. Everett, 38 Conn. 48; Davis v. Trump, 43 W. Va. 191, 27 S. E. 397, &4 Am. St. Rep. S49; Jennings v. State, 7 Tex. App. 35S; Ash v. I’ur- nell (Com. PI.) 11 N. Y. Supp. 54.