There are programs that can recover "deleted" files from a reformatted drive. I have one and have had to use it for clients. It works great - but not every person on the street is going to have it!

(My most recent successful use of it resulted in the hard drive, computer tower and my 1 terrabyte backup drive being taken by the RCMP due to illegal photos that were recovered. I called the police...they said I would get my backup drive back...I hope so!)