This is correct. Receiving summary judgement on the $4B isn't going to bring us out of bankruptcy. At least not on its own.
It is however the first piece of the pie. It is also a huge bargaining chip with JPM. They want to hold it as long as they can. Once the chips start to fall, it could go quickly. Some believe that JPM will settle while still holding the $4B, and use that as part of their settlement funds, which is certainly a possibility.
This post is my own opinion, and should not be relied on for your investment decisions.