While we at the same recovery topics
There are severals recovery sw out there that capable to retrieve formatted media but it depend on it's a regular image file (jpeg..etc) or Raw.
On my very last day at the Bosque, i formatted a 2Gb card with raw images which i thought i have already have them copied to external drive. Well, i didn't. The very same card was overwritten about 100 raw images the next week. I tried every possible solution out there and was able to recover partial raw images.
All of them can read some jpeg images back in the old days but Raw images is another story. One that specialize with camera raw can read raw files only if the formatted media that hasn't not been written the 2nd times, the rest of the typical recovery SW just report Raw files found but it;'s all corrupted. Because they can't assemble the header files correctly.
my experience was, If there media been formatted; you can the raw files back if new allocation hasn't been written. For the case of this photographer, he should able to get everything back from where i read. They only delete certain files, not even formatted or rewritten the card.
The free version is as good as paid version, they both got the same thing back, same speed and same amount of data.
For canon user, free raw files recovery worked as good as paid sw. Raw File will be retrieved in tiff format
http://www.z-a-recovery.com/digital-image-recovery.htm