We just had this error occur, causing a checkin to PlasticSCM to fail on a Windows client. There are many, many questions and answers regarding this error message in SO, but I'm posting this specifically for the issue we encountered during PlasticSCM checkin. Providing the answer below, as we were able to solve it.
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The solution for us was that one of the files in the checkin had a Windows path and file name in excess of 260 characters -- 264 to be exact -- which is more than the 260 character Windows limit. We shortened one of the directory names in that file's path, and that fixed it. It's not always an easy option to go renaming project directory tree paths, but if it's an option, that may solve this PlasticSCM error message. You'd think it would report the specific Windows error message about path length being limited to 260 characters, but it provided this rather misleading message instead.

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