Jennifer Mitkus allegedly lied to investigators shortly after Summers' disappearance, saying that she had been present at the final photo shoot that preceded Summers' disappearance.
Mitkus' lawyer, Carol Carluccio, asked the judge to release her client from custody.
"These charges carry no jail time whatsoever, and she's spent six weeks in jail on a bail that she cannot make," Carluccio stated in court.
According to local news station KYW, Mitkus is being held on charges of misleading police during an investigation and obstructing justice. She was originally suspected of being involved in the actual killing of Summers.
A judge is considering the bail request, although the prosecutor in the case is concerned that Mitkus, known to police as a local vagrant, will leave the state and possibly the country if released.
"This is a woman who was bouncing around from hotel room to hotel room with her cat in tow, working as a prostitute, with no known connection to the community," said prosecutor Risa Ferman in court arguments.
Mitkus was apprehended at the same time Frederick was arrested on first- and third-degree murder charges.
Summers, whose real name is Natel King, first disappeared on Feb. 29 after posing for Frederick in a bondage shoot that had been arranged over a website, prosecutors say. Summers’ body was found nearly a month later in a ravine in Whitemarsh, Pa. The body had been stabbed repeatedly and was wrapped in photography backdrop.
Summers was last seen walking to a corner bar in Conshohocken, Pa.
Detectives discovered bloodstained items in Frederick's car during the investigation. The District Attorney's office reported in April that the DNA analysis matched that of Frederick and Summers.
The death of Summers is still being linked to the making of a snuff film, although evidence confirming that theory has not yet surfaced.