Well, just deleting leaves things behind and spaces and when the unformatted card tries to write to it, instead of writing on one long sector, it has to jump around that junk left from just deleting and that's how you get errors!!! That's my unscientific explanation anyway
Hmmm, I'm unconvinced: My understanding was that when data is 'deleted', the actual data remains abandoned and largely unchanged on the disk, except that a flag is written, to: (a) make the filenames invisible to the OS, and (b) change the status of those liberated data sectors to 'now available to be overwritten anytime required'. So the HD Write-Heads have no obligation to slalom around mounds of newly-dead data. But there again, I'm always open to persuasion from the better-informed :-)