Email from Jason Callen, law clerk to Judge Frank Easterbrook, Seventh Circuit, to Jack Goldsmith and forwarded or blind-copied to Lawan Robinson, Confidential Assistant to the Assistant Attorney General, Department of Justice, Office of Legal Counsel.  Callen disagrees with John Yoo's op-ed in the Wall Street Journal stating that Article 5, Paragraph 1 of the Geneva Conventions applies to detainees in Iraq.  Callen instead believes paragraph 2 of that same article applies.  Paragraph 1 addresses detainees captured in the home territory of a belligerent power, whereas Paragraph 2 addresses detainees in occupied territories and gives detainees more protections.