Korda suggested the Bahamas, where the child was born and lives, has "substantial" say in how paternity of Smith's daughter should be determined, TMZ.com said.
Korda said he would rule "soon."
Smith's companion Howard K. Stern also claims to be the child's father and is listed as the father on the birth certificate. Zsa Zsa Gabor's husband, Prince Frederic von Anhalt, has a paternity suit pending as well and Smith's ex-bodyguard has also said he could be the father.
Smith died Feb. 8 in a Hollywood, Fla., hospital of unknown causes. A Broward County judge ruled Thursday that the legal guardian for her daughter should receive Smith's body.