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February 2026

| Feb. 1, 2026

Discipline Report

Feb. 1, 2026

February 2026

Recent attorney disbarments, suspensions, probations and public reprovals in California.

DISBARMENT

Jeffrey Ronald Brodey

State Bar #41831, North Hollywood (December 31, 2025)

Brodey, who had been charged with eight counts of professional misconduct, did not respond to the charges or participate in his disciplinary proceeding, nor did he move to have the default ultimately entered against him set aside or vacated.

The State Bar Court determined that all procedural rules had been satisfied, and that Brodey's wrongdoing warranted discipline. Upon entry of the default in the matter, the factual allegations were submitted, and the court found they supported culpability on all charges.

Brodey was found culpable of: failing to maintain complete records of client funds, failing to return unearned advanced fees, and failing to cooperate in the State Bar's investigation of the wrongdoing alleged, as well as two counts each of failing to deposit client funds in a trust account and failing to provide the court with an expenditure report as mandated. An additional count--intentionally misappropriating an advanced disbursement of expenses--was deemed to involve moral turpitude.

 

Vi Bui

State Bar #178436, Alpharetta, Georgia (December 31, 2025)

Bui was summarily disbarred based on his conviction of corruptly endeavoring to obstruct or impede the due administration of the Internal Revenue Code (26 U.S.C. § 7212(a)).

The offense is a felony. And the State Bar Court determined that it involved moral turpitude, reasoning that "compliance with the Internal Revenue Code would seemingly fall within 'the accepted rule of right and duty,' so that endeavoring to obstruct it could reasonably be considered contrary to that right and duty."

 

Kent H. Bulloch

State Bar #275515, Santa Rosa (December 31, 2025)

Bullock was disbarred by default after the State Bar Court determined that his disciplinary case fulfilled the required legal elements: proper service of the charges involved, actual notice of the proceedings, proper entry of the default, and a finding of a satisfactory basis for discipline.

He did not move to have the default entered against him set aside or vacated.

He was found culpable of a single count of professional misconduct: failing to file a timely declaration of compliance as required by the California Supreme Court in an earlier disciplinary proceeding (Cal. Rules of Ct., rule 9.20).

Bullock had been disciplined twice before being disbarred in the current case.

 

Edward C. Chen

State Bar #312553, Los Angeles (December 31, 2025)

Chen was disbarred by default after he failed to appear at the trial in which he was charged with 38 counts of professional misconduct in three consolidated matters.

Chen filed responses to the charges in two of the matters, but a default was entered after he failed to appear at trial. The court granted his motion to set the default aside "despite the motion being tardy and his minimal showing of good cause to justify setting aside the default." The case was abated due to an additional complaint pending against Chen, with the possibility of new charges.

A third case was subsequently filed and consolidated with the first two, but Chen again failed to appear at trial. He then moved to have the default in the consolidated cases set aside or vacated, but the court denied that motion., as well as Chen's motion to reconsider denying the motion to set aside the default. The court also denied Chen's petition for interlocutory review, finding that he failed to show an abuse of discretion or error of law in how the case was handled.

The factual allegations in the charges were then deemed admitted, and Chen was found culpable of all counts charged.

His wrongdoing included: failing to return unearned advanced fees, failing to promptly render an accounting of client fees upon terminating representation, failing to maintain complete records of client funds, failing to return client files after terminating representation, failing to obey court orders, failing to promptly disburse client funds, and representing a client with adverse interests to a former client in the same matter.

In addition, he was culpable of two counts each of failing to obey the laws and failing to cooperate in the State Bar's investigation of the wrongdoing alleged; four counts of failing to respond to reasonable client inquiries; five counts each of failing to act with reasonable diligence in representing his clients, improperly terminating representation, and failing to inform clients of significant case developments; and six counts of failing to deposit client funds in trust. Two additional counts involved moral turpitude: holding himself out as entitled to practice law while on inactive status and misappropriating a client's advanced fees.

 

Andrew Hoang Do

State Bar #147084, Santa Ana (December 31, 2025)

Do was summarily disbarred.

He earlier pled guilty to conspiring to commit bribery concerning programs receiving federal funds (18 U.S.C. § 371), and the conviction became final, evidenced by a certified copy of the docket showing Do did not appeal his sentencing.

The offense is a felony involving moral turpitude.

 

Matthew Charles Elstein

State Bar #174400, Redondo Beach (December 31, 2025)

Elstein was summarily disbarred based on his final conviction for committing wire fraud (18 U.S.C. § 1343).

The offense is a felony involving moral turpitude per se.

 

Anthony Dominic Garrido

State Bar # 285613, Roseville (December 31, 2025)

Garrido was summarily disbarred after the State Bar Court affirmed the finding of the Hearing Department that the facts and circumstances surrounding his felony convictions involved moral turpitude.

The evidence presented in the matter established that Garrido and his girlfriend had an altercation in which he lunged at her, pinned her to the bed, and them attempted to strangle her with a curtain rope cord. Garrido had also assaulted the woman a few months earlier--repeatedly shoving her and punching her in the chest.

The court reasoned: "The facts underlying Garrido's felony convictions represent a profound disregard for basic societal norms and duties of care that rise to the level of moral turpitude."

 

Aaron Thomas Gordon

State Bar #305013, Peach Springs, Arizona (December 31, 2025)

Gordon was disbarred by default after he failed to participate fully, either in person or through counsel, in his disciplinary proceeding in which he was charged with one count of professional misconduct: failing to file the declaration of compliance for suspended attorneys as mandated by the California Supreme Court (Cal. Rules of Ct., rule 9.20).  

The State Bar Court determined that Gordon had actual notice of the proceeding; he had appeared at an initial status conference, and later indicated he would file a response to the charges against him, but did not do so.

A default order was entered against him, which he did not move to have set aside or vacated.

Gordon had three prior records of discipline before being disbarred in the present case.

 

Hayk M. Grigoryan

State Bar #310348, San Pedro (December 31, 2025)

Grigoryan was disbarred after he stipulated to committing 16 acts of professional misconduct related to three separate matters.

His wrongdoing included: failing to maintain sufficient records of client funds and failing to render an account of them, failing to preserve client records as mandated, purposefully acting to delay or prolong a legal proceeding, failing to pay sanctions imposed and failing to report those sanctions to the State Bar, and failing to maintain the respect due to a court. He was also culpable of two counts of failing to maintain client funds in trust, as well as five counts of commingling personal and client funds in his trust account. An additional two counts of intentionally misappropriating client funds involved moral turpitude.

In one of the underlying matters, Grigoryan received a settlement check for $25,000. It was made payable to the "Grigoryan Law Firm," but the case had been handled by a different firm with his same last name and mistakenly mailed to him. Grigoryan deposited the check into his personal checking account and subsequently spent the funds on his personal expenses. He did not respond to calls from the insurer that had issued the check, and subsequently attempted to bargain with insurance representatives--falsely claiming he did work on behalf of the client. He repeated that claim to State Bar investigators, but was unable to produce any documentation to support his claim, such as a journal or ledger. The insurer, however, eventually agreed to accept a reduced restitution in the amount of $8,333--"with knowledge that respondent had not earned any of the funds and had not disbursed any of the funds to a client."

In a second matter, Grigoryan represented an individual and his business in defending against a personal injury claim; new counsel was subsequently substituted in to represent the individual. Though he signed a stipulation to continue a trial date in the matter as "counsel for defendant," Grigoryan failed to attend six court hearings or to respond to numerous communications from other counsel involved in the case.

And in the third matter, Grigoryan accepted $2,500 as an advanced fee in a wrongful foreclosure case. He initially deposited the funds into his client trust account, but then transferred them to his personal savings account. He filed a complaint in the case, but withdrew from representation a few months later--claiming he had earned the entire fee that had been advanced, but refusing to provide an accounting in the matter.

In aggravation, Grigoryan attempted to conceal his misappropriation of funds, failed to make restitution, and committed multiple acts of wrongdoing that harmed the administration of justice.

In mitigation, he entered into a pretrial stipulation and also received minimal mitigating credit for having practiced law discipline-free for four years.

 

Sara J. King

State Bar # 299115, Newport Beach (December 31, 2025)

King was summarily disbarred after the State Bar Court received evidence of the finality of her conviction for wire fraud (18 U.S.C. § 1343) and money laundering (18 U.S.C. § 1957). The offenses are felonies involving moral turpitude.

The facts contained in the plea agreement were that King operated a service purportedly providing short-term, high-interest loans to individuals with high net worths--including celebrities and professional athletes. The loans were guaranteed by her own assets, which included designer apparel, luxury automobiles, and yachts. King recruited investors to purportedly fund the loans, promising to sell the collateral if a borrower defaulted and to pass along a percentage of the interest along with the investors' initial investments. In reality, however, she never initiated or funded any loan, but used the funds to gamble at Las Vegas casinos and to support her lavish lifestyle. Five investors lost nearly $9 million through her scheme, for which she was sentenced to 21 months in federal prison.

 

Donald Richard Oder

State Bar #204920, Chula Vista (December 31, 2025)

Oder was disbarred by default. Though he participated in an initial status conference in his disciplinary case, he failed to appear at the trial in the matter, and a default was ordered against him. He did not move to have that order set aside or vacate.

He earlier entered a guilty plea to causing bodily injury while driving under the influence (Cal. Veh. Code  § 23153(a)). In the underlying incident, Oder caused a traffic collision when he ran a red light while making a turn and struck another vehicle. The crash caused significant injuries to a homeless woman living in the vehicle he hit. Oder failed to exchange insurance information at the scene, was driving an unregistered vehicle, and his blood alcohol tests showed levels ranging from .071 to .110.

The State Bar court found that the facts and circumstances surrounding the DUI conviction involved misconduct warranting professional discipline.

There was one additional disciplinary case and a separate investigation pending again Oder at the time he was disbarred in the instant case.

 

Britt David Zoolalian

State Bar #128231, Tustin (December 31, 2025)

Zoolalian was disbarred by default after he failed to file a response to the disciplinary charges against him or to move to have the default ultimately entered against him set aside or vacated.

The State Bar Court determined that the charges had been properly filed and served on Zoolalian, constituting adequate notice, and that the default in the case complied with all legal requirements.

As a result, the factual allegations in the charges were deemed admitted, and Zoolalian was found culpable of two counts of professional misconduct: engaging in the unauthorized practice of law and impermissibly commingling funds in his client trust account by failing to promptly remove earned fees and instead issuing four payments from the account to pay his personal expenses.

 

 

SUSPENSION

Boris Bindman

State Bar #313382, Walnut Creek (December 31, 2025)

Bindman was suspended from practicing law for one year and placed on probation for two years after he stipulated to being culpable of committing 28 acts of professional misconduct related to six separate client matters.

His wrongdoing included: failing to perform legal services with competence, charging an illegal fee, and failing to deposit client funds in a trust account; two counts each of failing to keep clients informed of significant case developments and failing to render an accounting of client funds; four counts of failing to promptly refund unearned advanced fees; five counts of failing to act with reasonable diligence in representing clients; and six counts each of failing to respond to reasonable client inquiries and failing to cooperate and participate in the State Bar's investigation of the wrongdoing alleged.

The specifics of the six client matters differed, but followed a substantially similar fact pattern: Bindman was retained to handle various legal actions--most of them domestic violence matters--accepting advanced fees from clients, but then failing to deliver promised services or communicate effectively with them. In one case, he fashioned a fee agreement held out as a "true retainer," which in fact compensated only services to be performed rather than assuring his availability.

In aggravation, Bindman committed multiple acts of wrongdoing that significantly harmed his clients, and failed to make restitution to four clients.

In mitigation, he entered into a pretrial stipulation.

 

David E. Kenner

State Bar #41425, Encino (December 31, 2025)

Kenner was suspended for 90 days and placed on probation for two years after he stipulated to committing six acts of professional misconduct related to three separate client cases: failing to perform legal services with competence, failing to perform legal services with diligence, presenting claims that were unsupported by the law, failing to return unearned advanced fees, and failing to properly supervise an employee in conducting legal matters. He was also culpable of one act involving moral turpitude in connection with a conviction of criminal contempt.

In the matter involving contempt, Kenner was counsel of record in a case in which the discovery materials were subject to a protective order. Despite that stricture, he met with two members of the news media--and allowed them access to the online database procured by the defense in the case. While he had initially asked them to sign a copy of the protective order related to the discovery materials; they did so, but ripped up the signed document in Kenner's presence. He subsequently failed to represent to the court that the signed orders had been destroyed and that he allowed access to the discovery materials in contravention of the protective order encompassing them. Kenner was subsequently convicted of misdemeanor criminal contempt (18 U.S.C. §401(3)).

 

In another matter, Kenner represented an incarcerated individual, hiring an additional attorney to assist in the matter. That attorney prepared a petition nearly identical to one that the court had rejected previously; only four paragraphs of the 34 page filing were original. Kenner was aware of the copying and the errors in the document, but allowed it to be filed. The court denied the petition.

And in the third matter, Kenner failed to refund any part of the $52,750 in unearned fees owed to a client following termination of his employment.

In aggravation, Kenner had a prior record of discipline and committed multiple acts of wrongdoing in the instant case.

In mitigation, he entered into a pretrial stipulation.

 

Joe Alfred Luna

State Bar #310961, Rancho Mirage (December 31, 2025)

Luna was suspended from the practice of law for 30 days and placed on probation for two years after he stipulated to pleading guilty to several alcohol-related vehicle violations in two separate matters.

In one case, Luna was arrested after highway patrol officers found him parked in his SUV in a moving freeway lane; he admitted to the officers that he had last consumed alcohol while parked in the vehicle, and was unable to complete field sobriety tests at the scene. He was culpable of driving under the influence (Cal. Veh. Code § 23152(a)) and driving with a blood alcohol level of .08% or more (Cal. Veh. Code § 23152(b))--both with an admitted allegation of an alcohol concentration of .20% or more (Cal. Veh. Code 23538(b)(2)).

In a subsequent incident, Luna was arrested after highway patrol officers observed him weaving outside his lane while driving. He pled guilty to driving with a blood alcohol concentration of 08% or more (Cal. Veh. Code § 23152(b)) with an admitted allegation of an alcohol concentration of .15% or more (Cal. Veh. Code § 23578).

All violations are misdemeanors, which the State Bar Court determined did not involve moral turpitude, but found that they constituted misconduct warranting discipline.

In aggravation, Luna had a prior record of discipline and committed multiple acts of misconduct in the instant matter.

In mitigation, he entered into a pretrial stipulation, and submitted evidence of performing substantial community service.

 

Gregory Paul Ricks

State Bar #140538, Tustin (December 31, 2025)

Ricks was suspended for 30 days and placed on probation for one year after he stipulated to committing four acts of professional misconduct: disobeying a court order, failing to report judicial sanctions imposed to the State Bar as required, disobeying a law, and practicing law while not eligible to do so--an act involving moral turpitude.

In a superior court case in which Ricks represented the defendant, the plaintiff and her counsel were awarded $13,700 in sanctions. Ricks failed to pay or to report the sanctions imposed to the State Bar. And in a case initiated by the State Bar, Ricks was advised to comply with Client Trust Account Protection Program reporting requirements, and to pay all outstanding noncompliance fees. After he failed to do so, he was placed on administrative inactive status. However, while suspended, he appeared in court three times on behalf of one client and filed a declaration on behalf of another client.

In aggravation, Ricks engaged in multiple acts of wrongdoing.

In mitigation, he entered into a pretrial stipulation, had practiced law discipline-free for approximately 34 years, and suffered from extreme emotional difficulties during the times of the misconduct prompted by his father's serious illness and a friend's suicide.

 

Mark Carl Watson

State Bar #178980, Burlingame (December 31, 2025)

Watson was suspended from the practice of law for one year and placed on probation for two years after he stipulated to committing seven acts of professional misconduct. His wrongdoing included commingling funds in his client trust account, failing to maintain complete records of funds received from clients, and engaging in the unauthorized practice of law. An additional four counts involved moral turpitude: three counts of misappropriating client funds and one count of holding himself out as entitled to practice law while on inactive status.

In one underlying matter, Watson represented a client in a real estate dispute. An agreement was entered that provided that the disputed property would be sold and the proceeds would be held in a designated account set up in Watson's name. He funded the account with a check from the escrow company in the amount of $1,329,044, then transferred $410,000 into the firm's account; the transfer was premature and unauthorized, as a settlement agreement had not been executed. Three checks from the designated account were also issued to members of Watson's firm. The balance in his client trust account, which should have included the amount of the parties' funds held without authorization, dipped to an impermissible level. Watson subsequently agreed to transfer the funds to an account maintained by opposing counsel and provided an accounting.

In another matter, Watson represented a client in a civil dispute, which was settled, with the client entitled to just over $9,222. Watson's firm erroneously sent the client check to the wrong address. Nearly two years later, after the State Bar informed Watson of the need to send a replacement check, he did so. The balance in his client trust account during that time dipped to an impermissible level.

Watson was placed on inactive status due to his failure to pay the reinstatement fee. However, he continued to practice law in at least one client matter while not authorized to do so.

In aggravation, Watson committed multiple acts of wrongdoing.

In mitigation, he entered into a prefiling stipulation, had practiced law for approximately 25 years without a record of discipline, submitted evidence of performing civic service, and provided letters from 10 individuals taken from the legal and general communities--all of whom attested to his good character.

 

 

PROBATION

Dennis W. Chang

State Bar #135613, Huntington Beach (December 31, 2025)

Chang was placed on probation for one year after he stipulated to committing four acts of professional misconduct. They included: failing to maintain client funds in a trust account, two counts of mismanaging funds in his trust account, and one count of willfully misappropriating client funds--wrongdoing involving moral turpitude.

Relevant facts in the case: Chang represented a married couple who were selling their home. Their agreement provided that the proceeds from the sale would be deposited into Chang's client trust account, and could be transferred to a separate trust account.

He deposited $731,137 in sale proceeds into a trust account, and later transferred funds from that account into another account. After paying court-ordered attorneys' fees, the balance in the relevant account dipped to an impermissible level.

During the course of his representation in the case, Chang also commingled $103,068 by making direct payouts to third parties for personal and business expenses, using earned fees he had allowed to remain in the trust account--and commingled an additional $29,276 by depositing personal funds into the trust account.

In aggravation, Chang committed multiple acts of misconduct.

In mitigation, he entered into a prefiling stipulation, had practiced law discipline-free for approximately 32 years, acknowledged and accepted responsibility for his misconduct and took remedial measures to prevent a recurrence, and replenished the missing account funds. He also provided letters from seven individuals who attested to his good character and community service.

 

--Barbara Kate Repa

#389506

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