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To be perfectly honest, I would not recommend using OmniOutliner 3 for this unless you can break it up into small files. A file with that many entries and photos will likely have performance issues. I'm also not sure if there's an easy way to move your data over from FileMaker, but someone else here probably has more knowledge than me on that part.

Future features, some of which will be in OO4.0 like filtering and smart folders, will likely help depending on the situation. We'd also like to improve attachment handling. But none of that helps now and we're not trying to make OmniOutliner a database application which it sounds like is much better suited for this.