the context was that the article was written to individuals. it was sent as general information about data recovery, sanitizing, and wiping, not to the specific case. i interpreted carl as asking about data recovery in general.
as for the case specifically, it depends on how well they adhered to SOP. they are reported to have req'd that information is deleted in a way as to prevent its recovery. like our clients, they have standard software that is supposed to achieve this goal.
even so, computer forensics experts with the feds could easily resurrect quite a bit of information, if they wanted to.
see also: Andersen's "Client Engagement Information -- Organization, Retention and Destruction" at: http://www.arthurandersen.com/resource2.nsf/vAttachLU/PDF_PracticeAdministrationClientEngagementInformation/$File/PDF_PracticeAdministration-ClientEngagementInformation.pdf