What would cause a user to exceed the maximum number of objtMessage objects?

I'm receiving EventID 9646 from MSEchangeIS: Mapi session "/o=Granite State Cabinetry/ou=First Administrative Group/cn=Recipients/cn=JKilar" exceeded the maximum of 250 objects of type "objtMessage".  What are some possible causes for this?  Could it be virus related?  
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This is from another site:

" As per Microsoft: "A single MAPI session has exceeded the maximum number of objects of a given type. To prevent a single client from affecting the performance of the entire server, this MAPI session was terminated". See MSEX2K3DB, M842022, M899663, and the link to "Veritas Support Document ID: 271186" for details on this event. "

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