Oksana Grigorieva asked the court to remove one of Gibson's lawyers. The Russian musician had been trying to disqualify the actor-director's attorneys because she consulted with their firm in 2008 on a custody issue related to her son with actor Timothy Dalton.
Records show the court rejected Grigorieva's request to have the lawyer removed last week without hearing oral arguments.
Gibson and Grigorieva have been fighting over custody of their infant daughter for more than a year.
The Associated Press contributed to this report.