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METZGER & McDONALD PLLC

(formerly Prager, Metzger & Kroemer PLLC)

A PROFESSIONAL LIMITED LIABILITY COMPANY

ATTORNEYS, MEDIATORS & COUNSELORS

    Steven C. Metzger

    2626 Cole Avenue, Suite 900

    Direct Dial 214-740-5030

    Dallas, Texas 75204-1083

    Facsimile 214-523-3838

    smetzger@pmklaw.com

    214-969-7600

    214-969-7635

    www.pmklaw.com

July 18, 2005

    Securities and Exchange Commission

    450 Fifth Street, N.W.

    Judiciary Plaza

    Washington, D.C. 20549-1004

    Attn: Larry Spirgel, Assistant Director

    Carlos Pacho, Senior Assistant Chief Accountant

    Division of Corporation Finance

    Mail Stop 0409

    Re:

    CabelTel International Corporation (Commission File No. 000-08187; CIK No. 0000105744) B Form 10-K for the fiscal
year ended December 31, 2004

Gentlemen:

     On behalf of CabelTel International Corporation, a Nevada corporation
(“GBR” or the “Company”), attached is an appeal to the Office
of the Chief Accountant of an issue/ conclusion by the Staff of the Securities and
Exchange Commission, Division of Corporation Finance (the “Staff”)
relating to the proper accounting treatment by the Company of a transaction occurring
in October 2004 and accounted for as a reverse acquisition in the December 31, 2004
financial statements. Such appeal is being filed under the EDGAR system as
correspondence.

     If you would like to discuss any item concerning the referenced entity or the
correspondence filed herewith, please do not hesitate to contact the undersigned at
any time at 214-740-5030 direct. By copy of this letter, we are transmitting courtesy
copies to certain members of the Staff.

    Very truly yours,

    /s/ Steven C. Metzger

    Steven C. Metzger

SCM:ag

Enclosures

    cc:

    Gene S. Bertcher, President and Chief Financial Officer

    CabelTel International Corporation

    Bob Carroll, Staff Accountant

    Sondra Stokes, Associate Chief Accountant

METZGER & McDONALD PLLC

(formerly Prager, Metzger & Kroemer PLLC)

A PROFESSIONAL LIMITED LIABILITY COMPANY

ATTORNEYS, MEDIATORS & COUNSELORS

    Steven C. Metzger

    2626 Cole Avenue, Suite 900

    Direct Dial 214-740-5030

    Dallas, Texas 75204-1083

    Facsimile 214-523-3838

    smetzger@pmklaw.com

    214-969-7600

    214-969-7635

    www.pmklaw.com

July 18, 2005

Via EDGAR, Via Facsimile 202-772-9213

and Via Federal Express

Office of the Chief Accountant

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    CabelTel International Corporation (Commission File
No. 000-18704), CIK No. 0000105744 – Form 10-K for the fiscal
year ended December 31, 2004

Ladies and Gentlemen:

     The purpose of this letter is to enter an appeal to the Office of the Chief
Accountant of an issue/conclusion by the Staff of the Securities and Exchange
Commission, Division of Corporation Finance (the “Staff”) relating to the
proper accounting treatment by CabelTel International Corporation (formerly Greenbriar
Corporation) (the “Company”) of a transaction occurring in October 2004
and accounted for as a reverse acquisition in the December 31, 2004 financial
statements of the Company included in its Form 10-K for the fiscal year ended December
31, 2004.

     The Staff in a comment letter dated April 27, 2005 with respect to the Form 10-K
Annual Report of the Company rendered the following comment to the Company:

     “Form 10-K for the Year Ended December 31, 2004

     Note A. Acquisition of CableTEL AD, page F-8

     Staff Comment. It is unclear how you concluded to account
for the acquisition of CableTEL AD as a reverse acquisition under the
guidelines of SFAS No. 141, “Business Combinations,”
paragraph 17,

Office of the Chief Accountant

United States Securities and Exchange Commission

July 18, 2005

Page 2

prior to the transaction and exchange of shares being
approved by stockholders. Please tell us why it is appropriate citing
specific accounting literature, to count this transaction as a reverse
acquisition in your financial statements for the period ended December
31, 2004.”

     The Company responded by letter dated May 6, 2005, effectively advising that
Management of the Company believes that the acquisition was properly accounted for as
a reverse acquisition in the December 31, 2004 financial statements included in the
2004 Form 10-K. In subsequent conversations by telephone among the Staff (including
Bob Carroll, Carlos Puoco and Sondra Stokes) and Management of the Company, the Staff
has disagreed with Management’s conclusions for reasons which the Staff may well
provide. The result of those conversations and disagreement is the basis of this
letter of appeal to the Office of the Chief Accountant.

CHANGE IN CONTROL

Background — Facts

     On October 12, 2005, Greenbriar Corporation (now known as CabelTel International
Corporation) (“GBR” or “the Company”), entered into an
acquisition and exchange agreement (“the Acquisition Agreement”) with
certain individuals (the “Sellers”), pursuant to which GBR effectively
acquired 74.8 % of the common stock of Cable Bulgaria AD (now known as CableTEL AD)
(“CableTEL AD”) in exchange for 31,500 shares of Series J 2% Preferred
Stock which is to be exchanged into 8,788,500 shares of GBR common stock
(approximately 89% of the then outstanding shares) upon completion of certain
regulatory requirements. CableTEL AD is a foreign operating company providing cable,
internet and telephone services to the country of Bulgaria. The Company accounted for
the acquisition as a reverse acquisition effective October 1, 2004.

     Voting Rights - GBR utilized the Series J 2% Preferred Stock as consideration for
the acquisition in the interest of time due to the applicable requirements of the
American Stock Exchange (“AMEX”), which requires a stockholder vote (or
written consent by the requisite number) for significant issuances of common stock.
The AMEX requires a proxy or information statement to existing stockholders to approve
common stock issuances greater than 20% or preferred stock with conversion features
having a similar effect. The Series J 2% Preferred Stock was designed to fall below
those requirements so the Company could close the acquisition in a timely manner. The
Acquisition Agreement requires GBR to present to its current stockholders for
approval, no later than September 30, 2005, the acquisition

Office of the Chief Accountant

United States Securities and Exchange Commission

July 18, 2005

Page 3

and the proposed mandatory exchange of the Series J 2% Preferred Stock into
8,788,500 shares of GBR Common Stock, which would then constitute at least 89% of the
total issued and outstanding shares of Common Stock of GBR. The applicable provision
in the Acquisition Agreement follows:

12(b) Requisite Stockholder Approval of Transaction and any Subsequent Exchange; Voting
Agreement.

Notwithstanding any other provision of this Agreement, as soon as reasonably practicable and in no
event later than September 30, 2005, the Company shall have presented the transaction represented
by this Agreement, together with the proposed mandatory exchange of Preferred Stock for Common
Stock described below to its current stockholders in accordance with applicable requirements of the
Commission and the AMEX for a vote (or written consent by the requisite number) of such
stockholders to approve the transaction evidenced by this Agreement and a mandatory exchange of all
shares of Preferred Stock for shares of the Company’s Common Stock on the basis of 279 shares
of Common Stock for each share of Preferred Stock, to result in an aggregate of 8,788,500 shares of
Common Stock to be issued to the Holders (or their respective transferees) which shall then
constitute at least 89% of the total issued and outstanding shares of Common Stock of the Company,
all of which shall be subject to the listing requirements with the AMEX, but may not be required to
be registered pursuant to the Act.

     In the event the stockholders vote not to approve the acquisition or the mandatory
exchange of shares, the Acquisition Agreement addresses recission of the transaction and the method
and manner in which the respective equity interestes will be returned. The applicable section of
the Acquisition Agreement follows.

12 (c) Potential Recission.

In the event that the stockholders of the Company do not approve by the requisite number of votes
either the transaction covered by this Agreement or the mandatory exchange of shares of Common
Stock for shares of Preferred Stock described in (b) above, the Holder(s) of the Preferred Stock
shall have the option, exercisable by all, but not less than all Holders, at any time after
September 30, 2005 until 12:00 noon, local Dallas, Texas time on September 30, 2006 (herein called
the “Put Option”), to either (I) rescind in full and revoke the transaction covered by
this Agreement by returning all 31,500 shares of Preferred Stock to the Company upon which the
Company shall, within two Business Days, deliver back to such Holder(s) all equity securities of
any entity owning all of the ordinary shares and other securities of Tacaruna or of Cabletel, or (ii) deliver to the Company all 31,500 shares of Preferred Stock of the
Company and receive in exchange therefor all of the ordinary shares and other securities of
Tacaruna outstanding and owned by the Company such that such Holder(s) shall become the owner and
holder of all of the issued and outstanding securities of Tacaruna which in turn continues to own
Cabletel.

Office of the Chief Accountant

United States Securities and Exchange Commission

July 18, 2005

Page 4

     Under the terms of the Acquisition Agreement, the acquisition of CableTEL AD, the issuance of
Preferred Stock as interim consideration and ultimately the exchange to common stock is one
transaction completed in steps only to allow time to comply with regulatory requirements. Except
for the need to comply with AMEX requirements, the Company had sufficient votes of holders of
current common stock in favor of the transaction, principally from management members and certain
significant stockholders (aggregating approximately 59%), to ratify the transaction and effect the
share exchange immediately. Because of the stated intentions of the parties involved and the
stockholder votes already obtained, recission was considered remote. The AMEX has approved the use
of an Information Statement under Schedule 14C. The Company is prepared to submit a written
consent to a number of holders of common stock who hold a sufficient number of shares to achieve
the necessary votes in favor of approval of the exchange transaction. Also at the same time, the
Company is prepared to submit to the SEC the Information Statement to complete the share exchange
process once the SEC review of the Company’s financial statements is completed.

     Senior Management - In connection with the transaction, one of the Sellers has been named
Chairman of the Board of Directors of GBR and continues to serve on the Board of Directors and as
President of CableTEL AD which is the Company’s largest operating units with over 85% of the
Company’s revenues. Another of the Sellers also continues to serve on CableTEL AD’s
Board of Directors. No original members of GBR management or Board of Directors serve in any
capacity for CableTEL AD.

     Conclusion - On October 12, 2004 the Company completed the acquisition of CableTEL AD through
the exchange of equity interests that will ultimately entail approximately 89% of the
Company’s voting common stock going to the Sellers. At the time of the transaction,
ratification of the acquisition and exchange of the shares was assured with at least holders of 59%
of existing common shares indicating their intention to vote in favor. Therefore, in accordance
with SFAS No. 141 a business combination occurred with CableTEL AD being the accounting acquirer
due to the ultimate change in voting control of the Company and the dominant management positions held by
the Sellers after the transaction as a result of the acquisition.

ENTITIES INVOLVED

     Ownership Structure - While not mentioned in the Staff’s comment letter dated
April 27, 2004, in conversations with the Staff, the issue of combining entities was raised. The
shares of CableTEL AD owned by the Sellers were held by holding companies established

Office of the Chief Accountant

United States Securities and Exchange Commission

July 18, 2005

Page 5

to minimize income taxes by taking advantage of available tax treaties. The Sellers held
their interests in two privately-held U.S. corporations, Finley Equities, Inc.
(“FEINC”) and American Realty Management, Inc. (“ARM”). FEINC and ARM each
owned (and continue to own) an undivided one-half equity interest in Tacaruna BV, a Netherlands
company, which in turn directly owns 30% of CableTEL AD. Tacaruna BV also owns 64% of the equity
interest of Narisma Holdings, Ltd., a Cyprus company, which in turn owns the balance of 70% of
CableTEL AD. A diagram reflecting the current ownership is attached. The result is that only two
businesses and only two operating entities combined. The other entities have no operations or
assets other than their stock holding in the next entity down the chart.

     Paragraph 18 of SFAS 141 states that if more than two entities are involved in the business
combination then ...consideration also shall be given to which combining entity initiated the
combination and whether the assets, liabilities and earnings of one of the combining entities
significantly exceed the those of the others. In this case CableTEL AD has the most assets,
liabilities and operating activity. The only businesses being combined are the Company (the former
Greenbriar Corporation) and CableTEL AD, the other entities are only holding companies created and
maintained for income tax management.

     Conclusion - The holding company entities acquired along with the interest in CableTEL AD are
not significant in the determination of the acquiring entity. In this case the operating entity
CableTEL AD is the acquiring entity.

OTHER ISSUES

     Passage of time - In our initial discussion with the Staff, the passage of time from the date
of the acquisition until the present time was raised by the Staff as consideration in concluding
that the transaction was not a single event. Immediately after the acquisition the Company began
working on the required Form 8-K filing. Upon completion of the Form 8-K (filed on December 27,
2004) the Company immediately began the process of standardizing accounting procedures and
gathering information in preparation for the combined companies first Form 10-K. Immediately after
filing the Form 10-K (on April 15, 2005) the Company completed the information statement and was
preparing to submit to the SEC and AMEX when the SEC comment letter was received on April 27, 2004.
Filing the information statement and completing the transaction (effecting the exchange) have been
suspended during the SEC review process.

     The Company has been working on completing the transaction without pause since the closing
date. Since the Company has only four corporate employees, a certain period of time

Office of the Chief Accountant

United States Securities and Exchange Commission

July 18, 2005

Page 6

to complete the process is not unreasonable. In consideration, the acquisition agreement
allowed until September 30, 2005 to complete the process. Delaying the filing of the information
statement (which will contain the Company’s December 31, 2004 financial statements) during
the SEC review process is an appropriate delay. Therefore, the passage of time from the initial
acquisition date until present is not (and should not be) a consideration in the accounting
treatment.

     Stockholders in common - During our discussions wi