I was trying to stay away from story quests and do nothing but side quest/exploration. This is no feat, but I hit 36 before I played chapter 4 and fought the Titan. Then I lost my car, YOU kidding me?!? Big hint for gamers, complete the chocobo quest BEFORE chapter 4. Makes things easier.
Edit: [spoiler]Found MP3, and got my car back, sneaking around was fun.[/spoiler]
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Best get the majority of side quests done anyway. I was overlevelled to the point I completed the game with ease. Got 5 achievements left which is a plus.