According to John Simon, the three most important things to do when taking a deposition are to listen, listen and listen. But after that, what makes the difference between a depo that covers the facts and a depo that closes the case? Attorneys John Simon, Tim Cronin and Erich Vieth discuss when to deviate from your outline, what to do if opposing counsel tries to intimidate you, and why it’s important to get non-verbal responses into the record.