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FILE - In this Sept. 24, 2012 file photo, Ariel Winter attends the World Premiere of "Batman: The Dark Knight Returns Part 1" at The Paley Center for Media, in Beverly Hills, Calif. Court records show a judge in Oct. 2012 stripped Winter's mother of custody temporarily amid allegations she has been physically and emotionally abusive to the 14-year-old "Modern Family" star. (Photo by Richard Shotwell/Invision/AP, File)

FILE - In this Sept. 24, 2012 file photo, Ariel Winter attends the World Premiere of "Batman: The Dark Knight Returns Part 1" at The Paley Center for Media, in Beverly Hills, Calif. Court records show a judge in Oct. 2012 stripped Winter's mother of custody temporarily amid allegations she has been physically and emotionally abusive to the 14-year-old "Modern Family" star. (Photo by Richard Shotwell/Invision/AP, File)