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During the 1/23/12 edition of Monday Night RAW, Kane gave Zack a choke slam on the top of the ramp with such force that Zack crashed through the top of the set. Since then Kane has delivered several more beatings to Zack which have not allowed his back to get a chance to heal. In February, Zack, while using a wheel chair and wearing a back and neck brace, was wheeled off the top of the ramp by Kane. Zack's "injuries" are all part of a storyline and there is no timetable for his return.
Source: http://prowrestling.about.com/od/whatsrealwhatsfake/a/wrestlingdl.htm