I have written a custom migration tool using SharePoint web services to move SP content from 2003 to 2007. I'm using solution suggested by Steve Curran
to set the tp_Modified field to Read_Only="False", update the Modified field with UpdateListItems(), then set back to Read_Only. This solution is working perfectly for SharePoint Versions 188.8.131.5219 and 184.108.40.20621. However
moving to a new SharePoint instance, 12.0.06545, the call to UpdateListItems returns 0x81020030. ("Invalid file name"). This fails only for document libraries.
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