He can spawn while you are in town just like any other unique. Three special cases: Maggot is the only one that can spawn in town (and only in town) and Sauron can spawn only at 99 and Morgoth at 100. Everything else can spawn everywhere except town.
Game actually has 100 levels before M: 0, 1, 2, 3. Town is level zero.
Game actually has 100 levels before M: 0, 1, 2, 3. Town is level zero.
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