Epic Level Lich? I dont know!

[Numion]

Now, I don't have ELHB, but in the latest (?) Dungeon magazine adventure some of the giants have epic feats, though they are under epic level. (But thier level + HD add up to 21+). The adventure was written by WotC staff, so they should know. (James Wyatt).

And don't scream spoilers, this wasn't one.