Quote from Phoebe in The One with Rachel's Inadvertent Kiss
Monica: Phoebe, you have a twig in your hair. Phoebe: Oh. Um, we kind of took a little detour on our way over here. Gary: Yeah. We were strolling through the park and no one was around, so. Monica: You didn't. Phoebe: We did! We violated section 12, paragraph 7 of the criminal code.