Terence Darrell Kelly, 36, faced Carnarvon Magistrates Court on Friday to answer one charge of assaulting a public officer in November last year.
Court records indicate Kelly pleaded not guilty to the charge in an appearance via videolink from custody.
The matter will return to the Carnarvon court on May 23.
Kelly in January admitted to abducting Cleo from her family's campsite, pleading guilty to one count of forcibly taking a child under 16.
Details of the kidnapping are expected to be outlined, along with a possible sentencing date, when the matter is transferred to Perth District Court in May.
Cleo was found alive in early November, 18 days after she went missing from the remote Blowholes campsite.
Her disappearance had sparked a major police investigation which eventually led detectives to a property in Carnarvon, just minutes from Cleo's family home.
Officers forced entry and found the little girl alone in a room, playing with toys.
The dramatic rescue was captured by an officer's body-worn camera and subsequently made news headlines around the world.
Prosecutors allege Kelly assaulted a police officer in Carnarvon on November 4 - the same date on which he first faced court over Cleo's disappearance.
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