I'm wary of upgrading any production server. Its an accident waiting to happen. Usually when I upgrade an OS on a server (PC Hardware FreeBSD), I have a test server I install on, get it running the test environment, move the users to it, and then upgrade the production hardware. Granted this is not easy with any Apple equipment, as its really expensive. I just wanted to show how far some are willing to go to avoid "upgrading". If your uptime is a must, doing it this way is really a must too.
It works really nice if you have a SAN environment with a nice fiber switch. No need to migrate the users, just put a new server on the SAN "network" and point things in the right direction. That was how my old mail environment was at my old job. We moved to at least 5 different front ends in around a 6 month time frame. No one other than the admins knew it was different until we sent an email to the users telling them the mail environment was upgraded.