4. Investigatory records.

The Act specifically exempts records dealing with law enforcement agency investigations. § 552.108. This exception generally covers offense reports and personal history and arrest records maintained for internal use. See Houston Chronicle Publ'g Co. v. City of Houston, 531 S.W.2d 177, 185 (Tex. Civ. App.-Houston [14th Dist.] 1975, writ ref'd n.r.e.). The first page of most common offense reports, however, is public when it includes information about the offense committed, crime location, identification and description of complainant, time of occurrence, property, premises and vehicles involved, description of the weather, a detailed description of the offense, and the names of the investigating officers. Houston Chronicle Publ'g Co., 531 S.W.2d at 186-87. Although prior opinions of the Attorney General supported the proposition that material is far less likely to be exempt under section 552.108 when an investigative file is closed, see, e.g., Tex. Att'y Gen. ORD-378 (1983), the Texas Supreme Court concluded that the "statute's plain language does not discriminate between 'open' and 'closed' files," holding that section 552.108's "blanket exemption" does not require district attorneys to disclose internal records, whether open or closed, that deal with detection, investigation, or prosecution of crime. Holmes v. Morales, 924 S.W.2d 920, 925 (Tex. 1996).