This is really strange... I did a test as you asked, and here is the results:
I did a fresh restart of the tablet. Opened Aqua Mail, and downloaded 12 attachments, attached to 7 different emails. Then opened the file manager (ES File Explorer), and noted the date and time attributes of each of the files. I then went back into Aqua Mail to check that all files were still linked (all still had the stiffy icon). I then restarted the tablet, and immediately went back into ES File Explorer and wrote down the date and time attributes. I never opened any other application. Of the 12 files, eight had different time stamps. Their new time stamp was exactly one second less than the original time stamp. Four had the same details as originally, and they were still linked in Aqua Mail.
The Results:
File 1 2012-12-08 15:52:27 New: 15:52:26 (no longer linked in Aqua Mail)
File 2 2012-12-08 15:52:59 New: 15:52:58 (no longer linked in Aqua Mail)
File 3 2012-12-08 15:53:28 New: 15:53:28
File 4 2012-12-08 15:52:35 New: 15:52:34 (no longer linked in Aqua Mail)
File 5 2012-12-08 15:53:23 New: 15:53:22 (no longer linked in Aqua Mail)
File 6 2012-12-08 15:53:06 New: 15:53:06
File 7 2012-12-08 15:52:25 New: 15:52:24 (no longer linked in Aqua Mail)
File 8 2012-12-08 15:52:53 New: 15:52:52 (no longer linked in Aqua Mail)
File 9 2012-12-08 15:52:46 New: 15:52:46
File 10 2012-12-08 15:53:17 New: 15:53:16 (no longer linked in Aqua Mail)
File 11 2012-12-08 15:53:22 New: 15:52:22
File 12 2012-12-08 15:52:27 New: 15:52:26 (no longer linked in Aqua Mail)
Looking at these results I'm noticing something really odd... All of the files which originally had uneven seconds in their time attribute had a new time attribute with even seconds after the restart. What on earth could cause this..?
Update: I did a firmware flash with the latest firmware for the tablet, and even after a fresh firmware flash with no other new applications installed, the tablet changes all files with an uneven timestamp to an even seconds timestamp... Even tried the two previous firmware versions, and they do the same. This is really odd... And I have no idea how to get around this problem!