I have been working with this client for about 5 months now. He was hit hard by penguin but he also received an un-natural links notice prior to that.
He has recovered slightly as I mentioned getting to the 2nd page, this happened months ago, could have been around the time of a penguin refresh.
Google is rejecting his reconsideration requests, so I assume if they were happy with the amount of links removed, they would state such.
By the way, I have recovered clients from panda and it happened in between panda refreshes. I know of others that have recovered from panda before a refresh as well.
One of my very own sites that has been steadily recovering from panda slowly has also seen improvements between panda refreshes.