But Campbell's lawyer, David Breitbart, said this was an "insult" because she earns "at least seven figures a year".
He added: "She is probably the most recognisable and prominent model in the world. There is no place that she could go that she would not be recognised." He added she needed her passport as she was due to fly to South Africa today for a charity event with Nelson Mandela.
Campbell was released, with her passport, and ordered to return to court on 27 June. She was also banned from contacting the alleged victim in any way.
It is not the first time the supermodel has been involved in rows with her staff.
In 2000 she pleaded guilty to attacking her personal assistant Georgina Galanis whom she hit with a phone and threatened to throw out of a moving car in Toronto. She was given an absolute discharge and paid an undisclosed sum to her former employee.
The same year another PA, Vanessa Frisbee, said she had also been attacked during an argument, and in 2003 an aide sued after claiming Campbell had thrown a mobile phone at her.
In August 2004, police in New York recorded an allegation by Campbell's housekeeper Millicent Burton that she had been punched and scratched during an argument over packing a suitcase.
But Campbell also made a complaint of harassment against her 44-year-old employee,and no further action was taken.
This month she started suing a cosmetic surgeon for £50,000 for articles printed in Hello! magazine giving the impression she endorsed him.
She sued the Daily Mirror for invading her privacy in photographing her leaving a Narcotics Anonymous Meeting and threatened legal action against a novel she felt mocked her.
Campbell was dumped by Elite model agency in 1993 when they sent out a stinging fax saying: "To Whom It May Concern: Please be informed that we do not wish to represent Naomi Campbell any longer. No amount of money or prestige could further justify the abuse that has been imposed on our staff and clients."
