In State Dep't. of Highways & Pub. Transp. v. Payne, 838 S.W.2d 235, 241, 35 Tex. Sup. Ct. J. 1197 (Tex. 1992), the Court held that, although the State requested an improperly worded jury-charge instruction, it was sufficient to preserve error. Id. at 241. The Court explained that "there should be but one test for determining if a party has preserved error in the jury charge, and that is whether the party made the trial court aware of the complaint, timely and plainly, and obtained a ruling. The more specific requirements of the rules should be applied, while they remain, to serve rather than defeat this principle." Id. Accordingly, parties have various opportunities to formulate the jury charge and preserve error about the charge before the trial court reads it to the jury. TEX. R. CIV. P. 273-74. And, after Payne, a party need only timely and plainly make the trial court aware of a complaint to preserve such error. Payne, 838 S.W.2d at 241. Consequently, Texas's rules for preserving jury-charge error raise little risk of erroneous deprivations