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You can make a character that has more than 20 levels without pulling an error in Hero Lab, you just can't have more than 20 levels in a single spellcasting class. For example you can make a Wizard 20/Fighter 20 just fine, and a wizard 15/cleric 15 is all good, but a wizard 15/cleric 15/mystic theuge 6 will have problems.
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