In pleading. The statement of matters of fact dlrectly (excluding the necessity of inference or argu-ment to arrive at the meaning) and in such appropriate terms, so arranged, as to be comprehensible by a person of common or ordi-nary understanding. See Merrill v. Everett, 38 Conn. 48; Davis v. Trump, 43 W. Va. 191, 27 S. E. 397, 64 Am. St Rep. 849; Jen-nlngs v. State, 7 Tex. App. 358; Ash v. Pur-nell (Com. Pl.) 11 N. Y. Supp. 54