10.  After Triage placed Mr. Kwiatkowski at Exeter Hospital, Plaintiffs French, Cross, Jordan  and Burke underwent procedures in the cardiac catheterization laboratory at Exeter  Hospital and were exposed to hepatitis C by Mr. Kwiatkowski.   11.  Upon information and belief, prior to arriving at Exeter Hospital, staff members at some  of the hospitals where Mr. Kwiatkowski had previously worked reported that Mr.  Kwiatkowski often told stories about himself that later proved to be false. For example,  Mr. Kwiatkowski frequently claimed that:  a.  he played baseball at the University of Michigan;  b.  his fiancée had died under tragic circumstances; and  c.  he suffered from cancer.   12.  Upon information and belief, prior to coming to Exeter Hospital, Mr. Kwiatkowski was  terminated by another hospital for falsifying information on a timesheet.    13.  Upon information and belief, prior to coming to Exeter Hospital, on at least two  occasions, needles were found in a restroom outside the cardiac catheterization laboratory  at a hospital where Mr. Kwiatkowski worked. After Mr. Kwiatkowski left that hospital,  no further such incidents occurred.    15.  Upon information and belief, Mr. Kwiatkowski tested positive for hepatitis C in June  2010.   16.  Hepatitis C is a blood-borne viral disease that is primarily transmitted by exposure to  infected blood. Left untreated, hepatitis C causes inflammation of the liver and can lead  to cirrhosis and/or liver cancer.   17.  Upon information and belief, in October 2011, after Mr. Kwiatkowski had been working  in its cardiac catheterization laboratory for six months, Exeter Hospital hired Mr.  Kwiatkowski as a full time cardiac catheterization laboratory technician.   18.  Upon information and belief, in or about May 2012, medical staff at Exeter Hospital  learned that several patients had tested positive for hepatitis C. Further investigation  revealed that all of these patients had undergone recent procedures in Exeter Hospital’s  cardiac catheterization laboratory.   19.  Upon information and belief, in June 2012, Mr. Kwiatkowski fled the state of New  Hampshire and was subsequently admitted to a psychiatric hospital in Massachusetts.   20.  As of July 13, 2012, the New Hampshire Department of Health and Human Services has  announced that 32 people, including Mr. Kwiatkowski and Mr. Fowler, associated with  the Exeter Hospital cardiac catheterization laboratory have tested positive for hepatitis C.    21.  Over 1,200 patients, associated with Exeter Hospital in New Hampshire have been tested  and 32 patients have been identified who are infected with the same strain of hepatitis C  as Mr. Kwiatkowski.    22.  On July 24, 2012, the New Hampshire Department of Health and Human Services  announced that over 6,000 more Exeter Hospital patients will be tested for hepatitis C.   23.  Upon information and belief, Triage has placed Mr. Kwiatkowski in hospitals in several  other states.   24.  Upon information and belief, hundreds of patients in Kansas, Maryland, and Georgia  have begun the testing process.   25.  Upon information and belief, Michigan, Arizona and New York are currently identifying  hospitals where Mr. Kwiatkowski may have worked.   27.  The Plaintiffs repeat and re-allege each of the allegations contained in paragraphs 1  through 26 as if fully set forth herein.   28.  Triage owed a duty of care to the Plaintiffs to protect them against harm from its  employee, Mr. Kwiatkowski. Triage is responsible for protecting members of the public,  including the Plaintiffs, that Mr. Kwiatkowski would be expected to encounter.    29.  Triage failed to exercise reasonable care when it hired Mr. Kwiatkowski in view of all of  the circumstances surrounding the job Mr. Kwiatkowski was to perform at Exeter  Hospital and other hospitals. Triage failed to exercise the degree of care required related  to the severity of risk to the Plaintiffs.    30.  Triage knew or should have known of Mr. Kwiatkowski’s likelihood of causing harm to  the Plaintiffs when it hired Mr. Kwiatkowski. Triage failed to conduct a reasonable  investigation that could have found Mr. Kwiatkowski’s likelihood of causing harm to the  Plaintiffs.   31.  Triage’s breach of its duty was the proximate cause of the Plaintiffs’ injuries.  32.  The Plaintiffs repeat and re-allege each of the allegations contained in paragraphs 1  through 32 as if fully set forth herein.   33.  Triage owed a duty of care to the Plaintiffs to protect them against harm from its  employee, Mr. Kwiatkowski. Triage is responsible for protecting members of the public,  including the Plaintiffs, that Mr. Kwiatkowski would be expected to encounter.    35.  Triage knew or should have known of Mr. Kwiatkowski’s likelihood of causing harm to  the Plaintiffs when it retained Mr. Kwiatkowski. Triage failed to conduct a reasonable  investigation that could have found Mr. Kwiatkowski’s likelihood of causing harm to the  Plaintiffs.   36.  Triage’s breach of its duty was the proximate cause of the Plaintiffs’ injuries.  37.  The Plaintiffs repeat and re-allege each of the allegations contained in paragraphs 1  through 36 as if fully set forth herein.   38.  Triage owed a duty of care to the Plaintiffs to protect them against harm from its  employee, Mr. Kwiatkowski. Triage is responsible for protecting members of the public,  including the Plaintiffs, that Mr. Kwiatkowski would be expected to encounter.    39.  Triage failed to exercise reasonable care in view of all of the circumstances surrounding  the job Mr. Kwiatkowski was to perform at Exeter Hospital. Triage failed to exercise the  degree of care required related to the severity of risk to the Plaintiffs.    40.  Triage knew or should have known of Mr. Kwiatkowski’s likelihood of causing harm to  the Plaintiffs when it supervised Mr. Kwiatkowski. Triage failed to conduct a reasonable  investigation that could have found Mr. Kwiatkowski’s likelihood of causing harm to the  Plaintiffs.   41.  Triage’s breach of its duty was the proximate cause of the Plaintiffs’ injuries.  42.  The Plaintiffs repeat and re-allege each of the allegations contained in paragraphs 1  through 41 as if fully set forth herein.   43.  Triage owed a duty of care to the Plaintiffs to protect him against harm from its  employee, Mr. Kwiatkowski. Triage is responsible for protecting members of the public,  including the Plaintiffs, that Mr. Kwiatkowski would be expected to encounter.    44.  Triage failed to exercise reasonable care in view of all of the circumstances surrounding  the job Mr. Kwiatkowski was to perform at Exeter Hospital. Triage failed to exercise the  degree of care required related to the severity of risk to the Plaintiffs.    46.  Triage’s breach of its duty was the proximate cause of the Plaintiffs’ injuries.  47.  The Plaintiffs repeat and re-alleges each of the allegations contained in paragraphs 1  through 46 as if fully set forth herein.   48.  Triage made intentional misrepresentations concerning Mr. Kwiatkowski’s qualifications  and employment record.    49.  Such misrepresentations allowed Mr. Kwiatkowski to pose a danger to patients, including  the Plaintiffs, who were treated in Exeter Hospital’s cardiac catheterization laboratory  during all relevant times.    50.  As a result of Triage’s misrepresentations, the Plaintiffs suffered injuries.  8.  The Defendant, Triage Staffing Inc. (hereinafter “Triage”), employs and places health  care workers known as “travelers.” Triage hires these “travelers” and places them to work  at hospitals around the United States on a contract basis for short durations of time, often  approximately 13 weeks. Such “travelers” often provide short-term staffing assistance to  hospitals that Triage contracts with.    9.  Upon information and belief, Triage hired one David Kwiatkowski as a traveling cardiac  catheterization laboratory technician and, in March 2011, placed Mr. Kwiatkowski at  Exeter Hospital in Exeter, New Hampshire.   