Under the law one can do something intentionally --that is with knowledge what he/she is doing is wrong/illegal. But under the law one can also do something not intentionally but negligently and recklessness is a degree of criminal negligence. In order to be held liable under negligence, that person under the law had a responsibility or duty to do something, which he/she did not do. Corporate officers/directors all have a duty to their shareholders under state corporate laws, and a duty to see that sec rules are followed. All the pleading is doing is anticipating Plants defense that "I had no knowledge" by pleading alternatively that even if that is true, he must still be held responsible and liable under the statute because negligence is a violation as well. Think of you running down someone with your automobile and killing them. If you intentionally did it, its murder in the first degree. If you were not looking at the road ahead when you hit the pedestrian, you are then criminally liable for your negligence in not following the duty the law imposes upon you to always keep your eye on the road. The sec has a real easy case to prove in front of them.
