On August 3, 2010, Judge Randall Newsome of the United States Bankruptcy Court for the Northern District of California (Oakland Division) issued a Show Cause Order requiring Graham to appear and explain why he should not be disciplined as the result of his practice before the Bankruptcy Court. Graham was charged with violating numerous local court rules and California law by charging excessive fees, use of “cram down” loan modifications and the unauthorized use of cash collateral. As a result, he was disbarred from practice before the Bankruptcy Court in the Northern District of California.