Thank you, but this doesn't answer the question. Both my client and I wanted to skip the update. There can be a lot of valid reasons to skip the update a few times before running it. But in both our cases we got warnings that we had a limited number of times we would be able to skip the update. My client apparently exceeded that limit and was unable to open QuickBooks at all until she ran the update. 

My concern is, when did this start happening? I'd never noticed it before so I assume it started with R9 (since we were both updating to R10) but it might be older than that and I just never encountered it before.

That asked, i now have another question. Is there a setting I can access to turn this off? When QB is on a terminal server and the update requires a reboot, it is not possible to run the update except at specific scheduled times and this feature can cause substantial difficulties.