Plead a statute
Black's Law Dictionary · Henry Campbell Black, M.A. · 1910
Black's Law Dictionary
Pleading a statute is stating the facts which bring the case within it; and "counting" on it, in the strict language of pleading, is making express reference to it by apt terms to show the source of right relied on.
McCullough v. Co.lfax County, 4 Neb. (Unof.) 543, 95 N. W. 31.