Maxwell introduced a necessary minimum number of edges in terms of the number of vertices required for a graph to yield a Euclidean rigid generic framework in $\mathbb{R}^3$, this count was generalised to $\mathbb{R}^d$, for all $d\geq 1$. In this paper, we give the analogous minimum number of $k$-simplices, for all $0\leq k\leq d$, required for a pure $d$-dimensional simplicial complex to yield a volume rigid generic framework in $\mathbb{R}^d$, for all $d\geq 1$. In order to do so, we prove some basic facts about the volume rigidity matroid and use exterior algebraic shifting, a recently added tool to the study of volume rigidity. We later prove a volume rigidity Vertex Removal Lemma and use our count to strengthen the statement.