Sherryn Davis opted not to appear in Central Local Court on Thursday, remaining downstairs in the cells.
She has been charged with Gray's manslaughter, supplying a prohibited drug and stealing.
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The charge sheet alleges Davis supplied Gray with heroin.
It says she: "did cause the death of Ian Gray in circumstances amounting to manslaughter, to wit, an unlawful and dangerous act".
Ex-soccer star Gray, 46, was found dead in his Elizabeth Bay apartment on Monday night.
Supplying heroin
Concerned friends broke in to the Onslow Avenue home when he failed to turn up to appointments or answer his phone.
Davis was arrested at a premises on Darlinghurst Road, Kings Cross, on Wednesday morning.
Speaking outside the court, Superintendent Tony Crandell refused to reveal either the time or the cause of Mr Gray's death.
"I expect further detail in that regard will be forthcoming," he said.
He also refrained from commenting on the relationship between Davis and Gray.
"At this stage, the relationship, I'm uncertain of and I can't comment on that simply because it is before the court," he said.
