| avr |
I cannot see how you could reasonably write a challenge for an arbitrary group of gestalt level 20 PCs. For a start PCs could bypass the first layer entirely and plane shift to the 3rd, and that's just a 5th level spell.
That's without getting into the widely divergent capabilities possible for level 20 gestalt characters. Take the differences possible between midlevel characters and turn them up to 9000.