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A colleague of mine was faced with this error while doing mailbox moves as part of an SBS2K3 migration. Most of the mailboxes moved fine but a couple of them refused to move and and resulted in this error.
In the end we figured out that it was caused by the mailbox limit on the target system being lower than the one on the source (which had no limit set at all). It was only afterwards that I found this post from Neil Hobson confirming our findings.
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Exchange, SmallBusinessServer
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