Provincial Case File No. 13058, New Hampshire Stare Archives - Petition of Anna Foss
Article 1, footnote 47
In the spring of 1767, Anna Foss left her husband Zachariah Foss on account of alleged maltreatment and sought refuge in the house of her son, John Adams. Zachariah might have brought a habeas action against John requiring him to produce Anna, which would have resulted in an equitable ruling by the bench.