Maybe, it depends on the phone model and version of Andriod that it runs. Most decent phones now have full disk encryption enabled, and a factory reset will generate a new random key. So in most cases, it's a dead end.
There was a post, which I replied to. Then the OP went back and tried to completely change the original post making my response not make sense anymore. I rejected the edit in the moderation queue and it seems to have deleted the original unedited post too.
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