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KB Article: http://support.microsoft.com/kb/2025703
INTRODUCTION
Steps to reproduce the issue:
1.Map a drive to a network share that contains several sub-folders that contains images files or PDFs
2.Open an Explorer window and navigate to the parent folder.
3.Attempt to rename each folder successively, while drilling into the sub-folder contents.
4.Continue step 3 until an error dialog containing the following text appears indicating that the sub-folder cannot be renamed:
"The action can't be completed because the folder or a file in it is open in another program. Close the file or folder and try again."