an attempt of the Israeli Defense Force Judge Advocate General to provide a legal framework for these killings in 2002, clarifying in a legal opinion under which conditions Israel considered the targeted killings legal.63 Most of the killings of the Second Intifada took place in Area A,64 and different means were used to kill Palestinians such as; drones, snipers, missiles shot from helicopters, killings at close range, and artillery.65 It is estimated that between 2002 and May 2008 at least 387 Palestinians were killed by Israel through targeted killing operations; 234 targets, and 153 collateral casualties.66 Several of those killed were high-ranking Palestinians, but the majority of them were mid-level fighters.67 Many of those who were targeted knew that they were under threat and would often go on the run or in hiding. In the first months of the Second Intifada Israel would usually pass a list to the PA with the names of those wanted, and if they were not arrested by the PA, Israel would proceed to kill them.68 One of the most well-known targeted killings was that of Abu Ali Mustafa, the leader of the Popular Front for the Liberation of Palestine (PFLP) on 27 August 2001. He was killed when a US-made Israeli army Apache helicopter fired two missiles into his office as he sat at his desk in Ramallah.69 Regarding the Israeli policy of targeted killings against Palestinian leaders, shortly before his death, Abu Ali Mustafa said: "We all are targeted as soon as we begin to be mobilized. We do our best to avoid their guns, but we are living under the brutal Zionist occupation of our lands, and its army is only a few meters away from us. Of course we must be cautious, but we have work to do, and nothing will stop us."70 63 Gideon Alon & Amos Harel, IDF Lawyers Set ‘Conditions’ for Assassination Policy, Haaretz, 2 February 2002. The conditions are the following: there must be well-supported information showing the terrorist will plan or carry out a terror attack in the near future; the policy can be enacted only after appeals to the Palestinian Authority calling for the terrorist's arrest have been ignored; attempts to arrest the suspect by use of IDF troops have failed; the assassination is not to be carried out in retribution for events of the past. Instead it can only be done to prevent attacks in the future which are liable to toll multiple casualties. Available at: http://www.haaretz.com/idf-lawyers-set-conditionsfor-assassination-policy-1.53911 64 K.A. Cavanaugh, Selective Justice: The Case of Israel and the Occupied Territories, Fordham International Law Journal, Volume 26, Article 4, 2002 65 UN Special Rapporteur Philip Alston, op.cit. (A/HRC/10/24/Add.6), page 6 66 Ibid. 67 Steven R. David, Fatal Choices: Israel’s Policy of Targeted Killing, op. cit., page 5 68 Ibid., page 7 69 Haithem El-Zabri, In Memoriam: Abu Ali Mustafa (1938-2001). Available at: http://abualimustafa.org/ biography/ 70 World Heritage Encyclopedia, Abu Ali Mustafa. Available at: http://self.gutenberg.org/articles/eng/ abu_ali_mustafa 24