Thus, your client would be forced to use asynchronous SAN replication, but this would not be real-time data. This question is covered in particular detail in this Q&A on Search Tech:
http://searchstorage.techtarget.com/ateQuestionNResponse/0,289625,sid5_cid605062_tax297597,00.html
You should also note that Clustering is only available with Microsoft Enterprise and Datacenter Editions. Both Windows Server 2003, Enterprise Edition and Datacenter Edition will support server cluster configurations of up to 8 nodes. This change was made to allow increased flexibility for deployments: particularly for geographically dispersed cluster configurations, and to support N+I configurations (N active with I spare). N+I will be particularly important for supporting larger Microsoft Exchange Server deployments using Windows Server 2003 into the future.
If your client can afford the expensive involved (and I will relate that it is HUGE and more than the entire operating budget of many firms), then I recommend that you begin your research with an article on Windows IT Pro:
http://www.winnetmag.com/Articles/Index.cfm?ArticleID=24890&pg=1
I would also recommend that you review the Exchange 2003 Technical documentation library located here:
http://www.microsoft.com/technet/prodtechnol/exchange/2003/library/default.mspx