An independent Title IX investigation concluded that former Palmerton Area School District School Board President Earl Paules engaged in “severe, pervasive and objectively offensive” conduct toward Superintendent Angela Friebolin that “denied her equal access to the district’s education program,” according to a written determination issued Dec. 1.

The 15-page determination, prepared by attorney Katherine H. Meehan of the law firm Raffaele Puppio, found Paules responsible for 16 of 19 allegations, partly responsible for two and not responsible for one, related to conduct that occurred between December 2024 and July 2025.

Paules has strongly disputed the findings, maintaining he “never harassed anyone” and noting that the independent factfinder rejected the most serious claim of quid pro quo sexual harassment.

The investigation

The investigation was conducted under Palmerton Area School District Board Policy 104, which prohibits discrimination and sexual harassment based on sex and incorporates federal Title IX standards.

“This report confirms that due to the conduct of (Paules) as listed in the document, I have been denied equal access to the education program of the Palmerton Area School District,” Friebolin said in a written statement released following the determination. “It is a further statement of fact and a matter of public record that on Saturday, Dec. 6, the Board voted to take negative action on my employment status.”

Friebolin has served as superintendent since December 2024.

The decision-maker applied a “preponderance of the evidence” standard, which according to law websites is a legal threshold meaning it was more likely than not that the conduct occurred.

Origin of complaint and investigative process

According to the determination, Friebolin first raised concerns about Paules’ conduct during an executive session of the school board on July 15, 2025, at which Paules was present. The following day, Kalani Linnell Asroff, deputy Title IX coordinator, was appointed to oversee the process.

Supportive measures were implemented, including mutual no-contact orders. Paules did not attend a meeting in person while the investigation was being conducted.

Darren Snyder of Grand River Solutions was retained as an independent investigator, and Meehan was appointed as the independent decision-maker.

Friebolin submitted a signed formal complaint July 20, 2025.

Paules received a copy of the complaint July 28, and both parties were formally notified of the allegations and grievance procedures Aug. 11.

The investigator interviewed Friebolin and Paules on multiple occasions in August and September, as well as witnesses who agreed to participate. Documentary evidence collected during the investigation included written notes, text messages, call logs, witness statements and key card entry records.

An investigation report was issued Oct. 24 and provided simultaneously to both parties.

Findings

According to the findings, Paules frequently commented on Friebolin’s appearance, clothing and body. On one occasion, the report states, in March 2025, Paules stood uncomfortably close to Friebolin in her office and told her she had violated policy because she was “way too good-looking to be a superintendent.”

The decision-maker credited Friebolin’s account of that interaction and noted that Paules provided evasive responses when questioned by investigators.

The investigation cataloged numerous text messages sent by Paules that were deemed unprofessional. In May 2025, he texted Friebolin, “You’re my girl,” and in July wrote, “never fall in love with your superintendent, but the hair extensions almost got me.”

Friebolin’s responses to the text messages were not included in the report.

The report details that Paules frequently asked Friebolin what she was “hiding” under her suit jacket and “made hand gestures mimicking the curvy shape of a woman’s body while alone with her.”

According to the determination, Friebolin altered her workplace behavior as a result of the comments.

“(Friebolin) consciously kept her jacket on whenever (Paules) was around in an attempt to avoid further comments,” the report states.

Comments and conduct involving others

In addition to conduct directed toward Friebolin, the determination found Paules responsible for making repeated inappropriate comments about others while engaged in district business and in Friebolin’s presence.

The report describes the use of derogatory language, offensive remarks and inappropriate jokes unrelated to legitimate district operations. The decision-maker concluded that the conduct violated district policy prohibiting harassment and discriminatory conduct.

Witnesses interviewed during the investigation corroborated several of these allegations, according to the report. One witness told investigators that Paules had a history of making inappropriate remarks about employees and board members.

Authority and intimidation

The determination also examined allegations that Paules attempted to intimidate Friebolin by asserting his authority as board president.

The report cited communications in which Paules emphasized his position during disagreements with Friebolin. The decision-maker concluded that Paules was “responsible in part” for this allegation.

While the report found that Paules asserted his authority in a manner that was intimidating, the decision-maker did not find evidence that he attempted to use his position to coerce Friebolin into a sexual relationship.

“The evidence does not support the conclusion that those occasions were related to sexual manipulation, but rather had to do with work-related tasks,” the determination states.

Paules was found not responsible for one key claim: that he created a hostile work environment after Friebolin allegedly rejected romantic or sexual advances.

“From a review of the evidence, it can be concluded that (Paules) engaged in unwelcome flirtation towards (Friebolin) throughout the winter and spring of 2025, thereby creating a hostile work environment,” the determination states. “However, there is no evidence that (Paules’) behavior changed or became more negative following (Friebolin’s) rejection of his advances.”

The report states there was no clear point at which Friebolin expressly declined Paules’ behavior in a way that resulted in a change in his conduct. Instead, the determination concluded that tensions escalated during disagreements over district operations.

No-contact order violations

Two additional allegations involved violations of a mutual no-contact order imposed during the investigation.

One involved Paules’ presence at a July 30, 2025, meeting at Palmer Elementary School where Friebolin was working. The decision-maker found that Paules was not invited and refused to leave despite concerns raised by administrators.

A second involved conduct at an Aug. 5 school board meeting, where Paules engaged in one-on-one contact with a witness subject to a no-contact order and publicly discussed administrative evaluations.

Both allegations were sustained.

Remedies and restrictions

As a result of the findings, the determination imposed multiple remedies and restrictions on Paules, including prohibiting one-on-one meetings with Friebolin, requiring another person be present during necessary communications, barring comments about her appearance or personal life, and directing him to refrain from inappropriate or discriminatory remarks while engaged in district business.

The determination also requires compliance with the no-contact order and prohibits retaliation against Friebolin or witnesses.

Paules disputes findings

Paules issued a lengthy written response disputing many of the findings while emphasizing conclusions that he said supported his position.

“First and foremost, the only person affiliated with the Palmerton Area School District that I am romantically involved with is my wife and fellow school board member, Danielle,” Paules said. “I have maintained from the very beginning of this process that I never harassed anyone nor created a hostile work environment. Initially, I did not vote to hire the superintendent because I felt that we had a better in-house candidate from the school district. However, once she took on the job, I believed that she was doing good work for the district but when I disagreed with her on certain school district matters including making sure that the district complied with the school code, I was accused of sexual harassment.”

Paules said the decision-maker rejected what he described as the most serious allegations.

“The most outlandish allegations made against me were rejected by an independent factfinder including quid pro quo sexual harassment,” Paules said. “Specifically, the report notes that ‘there is no evidence’ that my behavior changed towards the superintendent for any reason other than disagreements regarding school district business.”

Paules said the determination confirmed he did not abuse his authority to pursue a sexual relationship.

“The factfinder also found that I never abused my position as a school board member or the school board president to manipulate the superintendent into a sexual relationship or a sexual encounter of any kind,” Paules said.

Paules said he believes the allegations were intended to silence him.

“All of these allegations were intended to silence me because I was doing my job as an elected official,” Paules said. “I have served two full terms on the school board and recently was re-elected to a third term by the people of Palmerton Area School District.”

Paules also criticized the investigation process.

“I think this investigation was designed and conducted to protect the school district from legal liability and was not a true factfinding investigation to discover the truth,” Paules said. “The investigator never spoke with the superintendent’s husband who she supposedly confided in while all of this harassment allegedly occurred.

“Also, the district did not take steps to secure text messages from private phones or private email accounts, which could have disproved many of these allegations. The school district informed me at the outset of this case that they would only look at emails from school email accounts. While the superintendent only provided some text messages between me and her, I voluntarily disclosed every text communication between me and her since she was hired as superintendent.”

Wife speaks out

Paules’ wife Danielle, who is also a Palmerton school board director, said she was asked to leave the room during a July 15 meeting of the board so (Friebolin) could present a complaint to the board.

“I refused and stated that I wanted to hear what was being said,” Danielle said in a statement to the Times News.

“At that meeting, the superintendent made several accusations against my husband. The school district’s solicitor was present, and I spoke directly with him during that meeting. I asked whether she had ever brought these allegations to him prior to that night. He confirmed that she had not.”

Danielle called her husband a “dedicated school board member who takes his responsibilities seriously.”

Danielle continued to defend her husband.

“From the beginning, I knew the accusations were false,” she said. “Despite that, my husband and I spent the last six months clearing his name and a significant amount of money responding to allegations that were unfounded.”

“I am not one that likes fighting, but this was one fight I was not going to let my husband walk away from,” she said.

No appeal or resignation

Paules said he does not plan to appeal the determination.

“I dispute many of the findings and conclusions of this report; however, there is very little reason for me to pursue an appeal at this point because the report was already widely disseminated within the school community and it was provided to the media within days of only a small group of people receiving a copy of it with explicit instructions not to share it with anyone,” Paules said. “No matter what the outcome of the appeal would be now you can’t unring that bell. I spent almost $30,000 to clear my name and defend myself from these allegations when I am serving in an elected position with zero compensation.”

He said he intends to continue serving on the board.

“I just started my third term and I look forward to many more years as a school director in this district,” Paules said. “I’m not going to be deterred from upholding my oath and looking out for our students and our taxpayers. I will speak up when necessary. I will ask questions when they need to be asked. I will not spend money needlessly or recklessly. I will continue to make sure that the district complies with the law. I will continue to support investments in our children’s futures and support our teachers, staff, and administrators who share our community’s values and goals to provide a quality education for all people.”

Cost

Palmerton Area School District has incurred around $45,000 in costs related to the Title IX complaint, according to invoices reviewed by the Times News.

Documents show the district has been billed a combined $32,664.87 by two separate firms between August and November 2025 to handle the “fact-gathering” and legal adjudication of the matter.

The bulk of the expense comes from Grand River Solutions, a firm retained to conduct an independent investigation. Invoices indicate the firm has billed the district $25,368.87 for services described as “PASD Board Matter 2025.”

Grand River Solutions acted as the primary investigator for the district. Their invoices detail extensive work including analyzing evidence, drafting reports, and conducting witness interviews. Investigators logged multiple trips to Palmerton High School in August for in-person interviews, billing the district for travel time and mileage.

The firm’s charges also include expenses for transcription services to document the recorded interviews.

In addition to the investigative firm, the district retained the legal services of Raffaele Puppio, a Media, Pennsylvania-based law firm. An invoice dated Nov. 11, 2025, lists a balance due of $7,296.00 for services regarding a Title IX complaint.

Meehan, an attorney with Raffaele Puppio, is listed on the invoices as providing counsel on the matter. Her work included reviewing board policies, communicating with both (Friebolin) and (Paules), and drafting decisions regarding “supportive measures” and appeals.

The investigation appears to have been most active in late summer. Grand River Solutions billed nearly $12,000 for September alone, a month in which investigators spent more than 50 hours drafting reports and reviewing evidence. By late October, the legal firm was reviewing the final investigation report and issuing instructions to the parties involved.

The district has also paid $12,731 to Sweet, Stevens, Katz and Williams, its own solicitor, related to the Title IX matter.