pleadings. The common counts in an action of assumpsit are so called, because they are founded on express or implied promises to pay money in consideration of a precedent debt; they are of four descriptions: 1. The indebitatus assumpsit. 2. The quantum meruit. 3. The quantum valebant. and, 4. The account stated. 2. Although the plaintiff cannot resort to an implied promise when there is a general contract, yet he may, in many cases, recover on the common counts, notwithstanding there was a special agreement, provided it has been executed. It is therefore advisable to insert the money counts in an action of assumpsit, when suing on a special contract.