I often am prevented from doing certain operations on ext2fsd mounted volumes; Windows reports "being used by another person or program". Most recently I accidentally deleted a file on a ext3 partition, and trying to restore it from the recycle bin gave this message. I also have the problem with a file that was downloaded and then moved. Trying to move it again is causing this problem. It seems there is something strange going on with the locking, but I haven't really narroed it down - initially I thought that it was keeping some kind of file open in the original location, preventing the restore. But in the second instance, I cannot move the file anywhere at all. Additionally, this persists across reboots and umount/mount.
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