"The district court must formulate jury instructions so that they fairly and adequately cover the issues presented, correctly state the law, and are not misleading." Abromson v. American Pac. Corp., 114 F.3d 898, 901 (9th Cir. 1997); see also Mockler v. Multnomah County, 140 F.3d 808, 812 (9th Cir. 1998). Nonetheless, the district court has substantial latitude in tailoring jury instructions, and thus a party is not entitled to any particular form of instruction, United States v. Lopez-Alvarez, 970 F.2d 583, 597 (9th Cir.), cert. denied, 506 U.S. 989 (1992), nor the precise words given in a proposed instruction. United States v. Romero- Avila, 210 F.3d 1017, 1023 (9th Cir. 2000); Pavon v. Swift Transp. Co., 192 F.3d 902, 907 (9th Cir. 1999); see also Swinton v. Potomac Corp., 270 F.3d 794, 805 (9th Cir. 2001), cert. denied, 535 U.S.1018 (2002).

It is also clear that a party is not entitled to a jury instruction that is unsupported by the evidence. Beachy v. Boise Cascade Corp., 191 F.3d 1010, 1013 (9th Cir. 1999), cert. denied, 529 U.S. 1021 (2000).

In considering a party's request to give jurors an instruction that defines a common word, the trial court should take into account "the obvious, almost banal, proposition that the district court cannot be expected to define the common words of everyday life for the jury." United States v. Somsamouth, 352 F.3d 1271, 1275 (9th Cir. 2003) (in criminal prosecutions for making false representations to Social Security Administration–viz., that defendant could not work, thereby entitling him to SSI benefits–no error for trial court to refuse to define "work"), cert. denied, 124 S. Ct. 2049 (2004).