December 10th, 2005 
Yes, files can still be recovered after a format (I have successfully done this for a client). You need to download the appropriate utility from the hard drives manufacturer (i.e Western digital) and write zero's to the drive. Then all the data will be completely unrecoverable.
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When you are right you cannot be too radical; when you are wrong, you cannot be too conservative. - Martin Luther King, Jr.