Campbell v. State (1970)
In Campbell v. State, 456 S.W.2d 918 (Tex. Crim. App. 1970), the Court of Criminal Appeals stated in a footnote that "most cautious trial judges now require that a copy of revocation motion be served upon the probationer at least 10 full days before the hearing unless the same is personally waived by the probationer and his counsel," and that "such practice would seem to be more fully in accord with the provisions of Articles 27.11 and 27.12."
The Court acknowledged in the same footnote that "there is no statutory requirement as to the length of time a probationer must have a copy of the revocation motion served upon him prior to a hearing thereon." Campbell, 456 S.W.2d at 920 n.3.