to create up to four naval bases on the island of Cuba, but only ever built one, at Guantánamo Bay. The Platt Amendment was repealed in 1934, which is why the Cuban government considers the U.S. occupation of Guantánamo Bay illegal. The detention facility in the Guantanamo Bay Naval Base is operated by the Joint Task Force Guantanamo (JTF-GTMO) of the Southern Command of the Department of Defense (DoD). Detention areas consisted of Camp Delta including Camp Echo, Camp Iguana, and Camp X-Ray, which is now closed. After Bush political appointees at the U.S. Office of Legal Counsel, Department of Justice advised the Bush administration that the camp could be considered outside U.S. legal jurisdiction, military guards took the first twenty detainees to Camp X-Ray on January 11, 2002. At the time, Secretary of Defense Donald Rumsfeld said the detention camp was established to detain extraordinarily dangerous people, to interrogate detainees in an optimal setting, and to prosecute detainees for war crimes. In practice, the site has long been used for enemy combatants. The DoD at first kept secret the identity of the individuals held in Guantanamo, but after losing attempts to defy a Freedom of Information Act request from the Associated Press, the U.S. military officially acknowledged holding 779 prisoners in the camp. The Bush administration asserted that detainees were not entitled to any of the protections of the Geneva Conventions, while also claiming it was treating "all detainees consistently with the principles of the Geneva Convention." Ensuing U.S. Supreme Court decisions since 2004 have determined otherwise and that U.S. courts do have jurisdiction: it ruled in Hamdan v. Rumsfeld on June 29, 2006, that detainees were entitled to the minimal protections listed under Common Article 3 of the Geneva Conventions. Following this, on July 7, 2006 the Department of Defense issued an internal memo stating that detainees would, in the future, be entitled to protection under Common Article 3. Current and former detainees have reported abuse and torture, which the Bush administration denied. In a 2005 Amnesty International report, the facility was called the "Gulag of our times." In 2006, the United Nations unsuccessfully demanded that Guantanamo Bay detention camp be closed. On 13 January 2009, Susan J. Crawford, appointed by Bush to review DoD practices used at Guantanamo Bay and oversee the military trials, became the first Bush administration official to concede that torture occurred at Guantanamo