In State v. Palmer (1977), 80 Ohio St. 3d 543, 1997 Ohio 312, 687 N.E.2d 685, the Supreme Court addressed situations where the entire proceeding has not been duly recorded. In Palmer, the Court stated: "in a number of cases involving death penalty appeals, the Court has clearly held that reversal of convictions and sentences on grounds of some unrecorded bench and chambers conferences, off the record discussions, or other unrecorded proceedings will not occur in situations where the defendant has failed to demonstrate that: (1) a request was made at the trial that the conferences be recorded or that objections were made to failures to record; (2) an effort was made on appeal to comply with App. R. 9 and to reconstruct what occurred or to establish its importance, and (3) material prejudice resulted in the failure to record the proceedings at issue." State v. Palmer, 80 Ohio St. 3d 543, 554, 1997 Ohio 312, 687 N.E.2d 685, 696.