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I assume this is a VS2010 designer issue. (Does not reproduce on MD.)
Create a new layout file, which will result in switching current document to this new file. Immediately close and try to delete it on the solution explorer. After some seconds a failure will be reported. "The file is in use by other program and cannot be deleted" (whatever in OS lang. specific message, I dunno what English Windows prints).
Tested with 4.2.3 beta.
*** This bug has been marked as a duplicate of bug 9132 ***
Today with the latest builds:
This issue does not exist, as now the exception does not appear when edit the layout axml file after opening it in the code editor.
Hence, closing this issue.