SECTION
15 OF THE SECURITIES ACT OF 1933
15
U.S.C. § 77o(15) (1988)
Every
person who, by or through stock ownership, agency, or otherwise, or who,
pursuant to or in connection with an agreement or understanding with one or
more other persons by or through stock ownership, agency, or otherwise,
controls any person liable under section 11 or 12, shall also be liable jointly
and severally with and to the same extent as such controlled person to any
person to whom such controlled person is liable, unless the controlling person
had no knowledge of or reasonable ground to believe in the existence of the
facts by reason of which the liability of the controlled person is alleged to
exist.