In our SEM studies, the particles of less than 30 nm and present under this layer will be shielded in the obtained SEM image so we do further EM technique like Transmission EM.
Of course you can grow layers with this thickness. You will just notice that the thicker you grow, the fewer people will still consider it "graphene" and the more will consider it "thin graphite".
I don't have written references on it, but I have been at conferences and PhD defenses at which people spoke about multi-layer graphene and in the Q&A segments there were often questions or comments in the mentioned direction, some rejecting the concept of calling anything but a single monolayer graphene and some limiting it to