In Labelle v. State, 720 S.W.2d 101, 108 (Tex. Crim. App. 1986) at 102-03, the State alleged (in its motion to revoke supervision) Labelle had committed a new criminal offense by removing and destroying a governmental record. The State's motion did not further describe that governmental record. On appeal, the Texas Court of Criminal Appeals held the State's motion failed to provide sufficient notice "in respect to specificity of the governmental record in question," and, therefore, the trial court erred by overruling Labelle's exception to the State's revocation motion. Id. at 106.