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Data recovery is all about how much money you have. Even a bent plate with a nail through it could probably be read. People have pulled drives out of lakes, fires (where sprinklers had gone off after the fire), and other unlikely situations and pulled at least fragments of files of the disk. There ain't much worth the cost of these procedures, but some people do specialize in them.
If my life depended on a hard drive being erased, I'd completely overwrite the disk with random data a dozen times, then physically take apart the drive and break it into as many pieces as possible, burn what I could and then spread the peices in dumpsters around town.
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