Gomez-Lopez v. Ashcroft, 393 F.3d , 886 (9th Cir. 2005) (good moral character statutory bar covers confinement in any facility"whether federal, state, or local"as a result of conviction, for the requisite period of time, falls within the meaning of [8 U.S.C.] 1101(f)(7).") (emphasis added).

NOTE: If the client received credit for time served prior to conviction, and would not otherwise be subject to the 1101(f)(7), you should preserve the argument that Arreguin-Moreno v. Mukasey, 511 F. 3d 1229 (9th Cir. 2008), and Matter of Valdovinos, 18 I&N Dec. 343 (BIA 1982), were wrongly decided. This issue is currently being litigated in the 10th Circuit.
Thanks to Ben Winograd.