Poppi Worthington's father may wish to give evidence via video link at an inquest into her death, after his lawyer claimed the Barrow supermarket worker is subject to "risk and intimidation on a daily basis".
The suggestion was made during the formal opening of a fresh hearing into the 13-month-old's sudden death in suspicious circumstances in December 2012.
Speaking at the pre-inquest hearing at The Courts, in Carlisle on Thursday, Mr Paul Clark, representing Paul Worthington, said a "thorough risk assessment" must be carried out by the coroner to ensure the safety of his client should he be called as a witness.
Mr Clark said: "I would ask your offices to conduct a risk assessment in respect of the witnesses that may be called to appear.
"There are a number of practical arrangements to consider including the likes of video link evidence.
"While it may be said to affect the quality of evidence for a jury, I would suggest that's entirely removed if the finder of fact is (the coroner) and I believe the level of risk and intimidation that Paul Worthington experiences on a daily basis outweighs that."
Mr Clark also argued that a formal judgment of fact by a leading High Court judge - who concluded on the balance of probability that Mr Worthington had sexually assaulted his daughter before her death - must be considered as "opinion evidence only" during the proceedings.
He added that Mr Roberts had no power to adopt the document published by eminent family court judge Mr Justice Jackson in January as the inquest gets under way later this year - stating the standard of proof within the family court was not high enough to meet the requirements of the coroner.
The hearing heard that Mr Roberts is to investigate whether the inquest into the death of the little girl, which will determine the medical cause of her death as well as how that cause came about, should be considered under Article 2 - a legal term used when it is believed the state may have owed a reasonable duty of care to the deceased.
He has ordered officials at Cumbria County Council to hand over all documentation relating to Poppi and her family between 2008 and 2013 as he looks into the issue.
Counsel Mrs Alison Hewitt, who is assisting Mr Roberts with the inquest, told the court: "The coroner is asking as a starting point for Cumbria County Council, as part of which we have social services, children's services and family services, to disclose whether they hold any records or documents relating to the mother, Paul Worthington, the siblings or Poppi from 2008 until the date of Poppi's death.
"These dates are because that is believed to be when the family unit of the mother and Paul Worthington first began."
A second pre-inquest hearing has been set to go ahead on July 25, by which time Mr Roberts is expected to confirm the number and names of witnesses he is likely to call.
He will also make decisions on whether the inquest will be considered as an Article 2 hearing as well as whether the High Court fact-finding judgment is to be adopted into evidence.
The inquest itself is expected to take place in October or November this year, lasting a week, though the location of the proceedings has not yet been confirmed.
The original inquest into the death of baby Poppi, which took place at Barrow Town Hall in October 2014 and lasted just seven minutes, was deemed irregular last year.
It concluded the cause of Poppi's death was unascertained, recording an open verdict.