Cir.1993) ("A party has the burden to request the submission of its issues to the jury and to request instructions on each such issue.... [Fjailure to object to the wording of a special issue prevents a party from objecting to such wording on appeal.”); Pan Eastern Exploration Co. v. Hufo Oils, 855 F.2d 1106, 1123 (5th Cir.1988) ("A party must ordinarily object precisely to the wording of jury instructions and interrogatories ....”). 9 . See Quillen v. International Playtex, Inc., 789 F.2d 1041, 1043-44 (4th Cir.1986) (refusing to hold that defendant had impliedly consented where evidence presented went to pleaded issue primarily; therefore, "the defendant would have been caught unaware” of the new issue); Trinity Carton Co. v. Falstaff Brewing Corp., 767 F.2d 184, 192 (5th Cir.1985) (<HOLDING>), cert. denied, 475 U.S. 1017, 106 S.Ct. 1202,
holding that burden was on nonmoving party to show issue was not litigated where moving party presented supreme court opinion showing issue had been litigated holding that trial by consent requires that the parties actually recognize the issue to have been litigated holding that all matters litigated or which could have been litigated in al foreclosure action are forever at rest  holding that burden was on nonmoving party to show issue was not litigated where moving party presented arbitrators order showing issue had been litigated holding that a civil claim is barred by collateral estoppel even though the prior adjudication was in criminal proceedings and the parties are not the same because the matters were actually litigated and decided in the prior trial