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No, to train efficiently a Pokémon it can be at any level below 100. I just EV trained a Lvl. 78 Gallade and it is really powerful. It's only like 3 points below its maximum Attack stat.
Did you train it up to level 70 in battles? If so, then it probably already has its EVs maxed out. If you don't know, talk to the Effort Ribbon lady in Sunyshore market. If you get the ribbon, its EVs are maxed.