If you define superficial fat as the fat we can liposuction
and deep fat as fat we cannot get to.
I would have to guess that your doctor is talking about fat inside the abdomen. This fat is behind the abdominal muscles and is intertwined with the intestines and other organs that would be injured by liposuction in this area. I do not usually call this deep fat, i call it fat that cannot be treated.
Within the superficial fat that we can liposuction, there are also two layers. When plastic surgeons refer to deep fat pockets, they are often referring to localized pockets of fat in front of the muscle fascia but deep to the superficial fascia. These areas are the safest places to liposuction. The most superficial fat has the highest risk of leaving dents, and requires the greatest skill.