Four men claim they may be the father of Smith's baby.
Larry Birkhead, a California photographer and former boyfriend, filed a paternity lawsuit. Howard K. Stern, Smith's companion, was listed on the child's birth certificate. Smith's body guard Alexander Denk said he, too, may have fathered the child.
In a news conference outside the courthouse in Santa Monica, Calif., von Anhalt called Smith's Bahamian wedding to Stern "a joke." Smith and Stern exchanged rings during a commitment ceremony in September.
Smith died Feb. 8 in a Hollywood, Fla., hospital where she was taken after being found unresponsive in her hotel room. A preliminary autopsy has not determined a cause of death.