Yep, it’s legal and in my humble opinion it is fair. The Army is in the process of drawing down personnel strength and they are trying to separate the wheat from the chaff. In your description of events, the verbal counseling and the formal counseling constitute two events. If the counselor referred to your verbal counseling session in his formal counseling he met the bar by documenting 2 events. It also appears the leader was doing his best to get your attention at the lowest possible level of correction by providing a verbal counseling. If the leaders of WLC are serious, they can remove you from the course.